Centralized services fees cannot be treated as Fee for Technical Services and hence not taxable

Starwood Asia Pacific Hotels Vs ACIT (ITAT Delhi) ITAT Delhi held that the centralised services fee received by the assessee cannot be treated as FTS under Article 12 of the India-Singapore tax treaty, hence, not taxable in India. Facts- The core issue arising for consideration is, whether the amount of Rs.6,00,80,312 received by the assessee towards various centralised services rendered to Indian customers is taxable as Fee for Technical Services (FTS)/royalty under Article 12 of India-Singapore Double Taxation Avoidance Agreement (DTAA). Conclusion- We find, the issue in dispute has been ela...