Home › Income-Tax Act › CIT (IT) v. Radisson Hotel Interaction Incorporated (2023) 454 ITR 816 (Delhi)(HC) Editorial: Notice issued in SLP filed by the Revenue, CIT (IT) v. Radisson Hotels International Incorporated (2023)454 ITR 819 (SC)

CIT (IT) v. Radisson Hotel Interaction Incorporated (2023) 454 ITR 816 (Delhi)(HC) Editorial: Notice issued in SLP filed by the Revenue, CIT (IT) v. Radisson Hotels International Incorporated (2023)454 ITR 819 (SC)

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Centralised services-Not fees for technical services or fees for included services-DTAA-India-USA.[Art. 12(4)(a)

Dismissing the appeal of the Revenue the Court held that   though the decision of this court in the Department ‘s appeal against the decision of the court in DIT v. Sheraton International Inc.(2 009) 313 ITR 267 (Delhi )(HC) is  pending before the Supreme Court there was no stay on the judgment till date. The Department had not brought anything to distinguish the judgment on facts. No question of law. (AY. 2016-17)