Training and computer reservation service cannot be treated as FTS

Asst. CIT Vs Renaissance Services BV (ITAT Mumbai) Held that the receipts of the assessee from training services and computer reservation services including reimbursements shall not be chargeable to tax both under the Act as well as under the Treaty. Facts- The assessee is a company incorporated in the Netherlands and is tax resident of Netherlands. The assessee is part of the Marriott Group. It is engaged in conducting training programs and providing access to various ‘Computer Systems such as Centralised Reservation Systems (CRS) to Marriott Chain of Hotels located worldwide. The cost and ...