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Case Law Details

Case Name : Ms/ Starwood Asia Pacific Hotels Vs ACIT (ITAT Delhi)
Appeal Number : ITA No. 8669/Del/2019
Date of Judgement/Order : 26/12/2022
Related Assessment Year : 2016-17
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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 Artic

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