S. 9(1)(vii) :Income deemed to accrue or arise in India-Fees for technical services-Marketing contribution, priority club receipt and reservation contribution with Indian hotels for using trade marks and providing support programs and systems-Fees received from Indian Hotels is not royalty-Addition is deleted-DTAA-USA.[Art. 12(3)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Reimbursement of expenses-Not fees for technical services-Living allowance-No employer and employee relation ship-Agency commission-Not liable to deduct tax at source-Article 12 of OECD Model Convention-Levy of interest is not barred by limitation. [S. 192, 194J 195, 201]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Providing hotel related services to hotels worldwide-Revenue is not in nature of royalty or fees for technical services —No Permanent Establishment in India-Receipt is not taxable as business income-DTAA-India-USA,[S.9(1)(i), 9(1)(vii),, Art. 7, 12(4)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Licensed software-Software packages like office 365, etc.-Amount paid to any use or right to use any copy right-Merely because tax was deducted at source u/s. 195 would not make payment liable to be taxed as royalty.[S.9(1)(vi), Expln 2(iva), 195]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Subscription fees received by the assessee from its customers for providing access to databases and journals were not royalty-DTAA-India-USA [Art. 12(3)

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Payments made for hiring dredgers on a time charter basis qualify as royalty for use of equipment-liable to deduct tax at source.[S.195]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-There is no entity which was habitually procuring contracts for non-resident assessee or to bind assessee for contracts to be entered by that entity independently-It could not be held that assessee had Dependent Agency Permanent Establishment in India-Profits are not liable to tax in India.[S. 5(2)]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Changed mode of business operations-Computerized reservation system services on behalf of Air lines and Hotels to travel agents in India-No agency permanent establishment-Profits is not liable to tax in India–DTAA-India-USA [Art.5, 7]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Operational staff and the Vessel and the captain of the vessel who originally belonged to the non-resident company and who had been sent to work under the complete control and supervision of the Assessee did not constitute a business connection for the non-resident in India-Article 5 of the OECD Model Convention.

S. 2(22)(e) : Deemed dividend-Loans and advances-Regular business transactions-Not share holder-Not taxable as deemed dividend.