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 &

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