Receipt from centralized service is not in nature of FTS hence not taxable in India

DCIT Vs Westin Hotel Management L.P (ITAT Delhi) ITAT Delhi held that revenue received by the assessee for providing centralized services is not in the nature of Fee for Technical Services (FTS) u/s. 9(I)(vi) Explanation of Income Tax Act, but it is a business income and since assessee is not having PE in India, the same is not taxable. Facts- The assessee is a non-resident Limited Liability Partnership (‘LLP’) incorporated in the United States of America (‘USA’) and is a resident of that country. Basically, the assessee is engaged in the business of providing various services to hotel...