Held, dismissing the appeal of the Revenue the Tribunal held that the  included services were ancillary or auxiliary in nature and being an integral part of the job undertaken by the assessee, they were neither independent of, nor separable from, the job undertaken by the assessee in relation to publicity, advertisement and sales promotion of the hotel business worldwide, which were the main services rendered by the assessee to the Indian company, keeping the use of trademark, trade name and other enumerated services incidental to the main service, and that, thus, the payments received were neither in the nature of royalty under section 9(1)(vi), Explanation 2 nor in the nature of fees for technical services under section 9(1)(vii), Explanation 2 but in the nature of business income not taxable in India owing to the absence of a permanent establishment for the assessee in India. Order of CIT(A)) is affirmed. (AY. 2021-22)