Marketing and reservation charges are not Royalty or FIS and they are in the nature of business income and since the assessee does not have a PE in India, the same are not taxable in India

Six Continents Hotels Inc. v DCIT

ITAT, Mumbai

IT (Appeal) Nos. 3618 and 3619 (Mum.) of 2008

Assessment Years: 2003-04 and 2004-05

Decided on: 11 May 2011

Order

N.V. Vasudevan, JM

1. ITA No.3619/M/08 is an appeal by the assessee against the order dated 19-3-2008 of CIT(A) XXXI, Mumbai r

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