Marketing & Reservation Fees Not Taxable as FTS under India-US DTAA: ITAT Delhi

Six Continents Hotels Inc. Vs ACIT (ITAT Delhi) Marketing & Reservation Fees Not Taxable as FTS under India-US DTAA- ITAT Delhi Rules in Favour of Six Continents Hotels Delhi Tribunal allowed the appeals partly, holding that Marketing & Reservation Contributions (MRC) received from Indian hotels by the US-based IHG group entity were not taxable as “Royalty” or “Fees for Technical Services (FTS)” under the Act or India-USA DTAA. Assessee, owner of hotel brands like Holiday Inn, Holiday Inn Express & Crowne Plaza, received MRC & other reimbursements from Indian franchisee...