AAR : Payments received by the Applicant from the Indian hotel owner for provision of global reservation services (‘GRS’) would be chargeable to tax in India as ‘Fees for Technical Services’or ‘Royalty’under the provisions of section 9(1)(vi) / 9(1)(vii) of the Income tax Act, 1961 (“the Act”) read with provisions of Article 12 of the Double Taxation Avoidance Agreement between India and Luxembourg
Authority Of Advance Rulings FRS Hotel Group (Lux) S.A.R.L. In Re Section 245Q(1), 9(1)(vi), 10.2 R.S. Shukla, In-Charge Chairman & […]