Payments from Indian Hotel Owner for Global Reservation Services is Business Income: AAR

In re FRS Hotel Group(Lux) S.a.r.l. (AAR Delhi) Issue- Whether on the facts and circumstances of the case, payments received by the Applicant from the Indian hotel owner for provision of global reservation services (GRS) would be chargeable to tax in India as “Fees for Technical Services” or “Royalty”under the provisions of section 9(1)(vi) / 9(1)(vii) of the Income tax Act, 1961  read with provisions of Article 12 of the Double Taxation Avoidance Agreement between India and Luxembourg? Held- The payments received by the Applicant from the Indian hotel owner for provision of global re...