Marketing & Reservation Fees to US Hotel Chain Not Taxable Under India-US DTAA

CIT (International Taxation) Vs Six Continents Hotels Inc (Delhi High Court) Delhi High Court has dismissed an appeal filed by the Income Tax Department (Revenue) challenging a tribunal order that had ruled against taxing certain fees received by Six Continents Hotels Inc. from Indian hotels. The High Court held that the issue was already settled by several of its own previous judgments concerning similar payments to international hotel chains, concluding that no substantial question of law warranted further consideration. The appeal stemmed from an order passed by the Income Tax Appellate Tri...