Payment for advisory services and opinions for improvement of existing facilities in the hotels for meeting international standards would not fall within ambit of ‘fees for included services’ under India USA Treaty

ACIT v Viceroy Hotels Ltd. ITAT BENCH ‘A’, HYDERABAD ITA Nos. 401, 436, 437, 482 AND 483 (HYD.) of 2007 G.C. Gupta, VP and Chandra Poojari, AM Decided on: 27 May 2011  Order Chandra Pooiari, AM There are five appeals in all in this bunch. Besides the appeal of the Revenue for the assessment year 2003-04, which is directed against the order of the CIT(A)-II, Hyderabad dated 26.12.2006, there are cross appeals preferred by the assessee as well as the revenue for the assessment years 2003-04 to 2005-06, which are directed against the common order passed by the CIT(A)...