Receipt in terms of Strategic Oversight Services Agreement cannot be termed as royalty

Hyatt International-Southwest Asia Ltd Vs ADIT (Delhi High Court) Delhi High Court held that the consideration received in terms of Strategic Oversight Services Agreements (SOSA) cannot be termed as Royalty under Article 12 of the DTAA even if extensive services are rendered which includes access to written knowledge, processes, and commercial information in furtherance of the services. Facts- The Assessee entered into two Strategic Oversight Services Agreements (the SOSA) with Asian Hotels Limited, India. In terms of the SOSA, the Assessee agreed to provide strategic planning services and ...