Held that the receipts of the assessee from various activities of hotel management ranging, inter alia, from ticketing, reservation, marketing, advertising, operation, administration, catering, network support services, portal services, imparting of skill sets through trainings, were not taxable as fees for technical services within the meaning and scope of section 9 of the Act or article 12 of the Double Taxation Avoidance Agreement between India and the United States of America. (AY.  2014-15)