Receipts from Centralised Service Income by Radisson Hotels International are not Taxable as FTS/FIS under Article 12(4)(a) of India-USA DTAA: ITAT [Read Order]

Receipt-Centralised Service- Income-Radisson Hotel-International-FTS-FIS- India USA DTAA -ITAT-taxscan

The Delhi Bench of Income Tax Act has held that the receipts from centralised service income by Radisson Hotels international would not be taxable as fees for technical services (FTS) or fees for included services (FIS) under Article Double Taxation Avoidance Agreement (DTAA). The assessee, Radisson Hotels International Incorporated was a non-resident corporate entity incorporated…

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