Exclusion of Management Support Services from Article 12(4) of India-Singapore DTAA

Inter Continental Hotels Group [Asia Pacific] PTE Ltd Vs DCIT (ITAT Delhi)

ITAT Delhi held that provision of management support services to various hotels in India doesn’t come under Article 12(4) of India -Singapore DTAA. Accordingly, addition unsustainable.

Facts- The assessee has preferred the present appeal contesting that the CIT(A) erred in treating the amount received by the assessee from Inter Continental Hotels Group [Asia Pacific] India Pvt Ltd [IHGAP] towards

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