Assessee, a US based corporate entity, was engaged in providing hotel services.Assessee had entered into two agreements with Indian hotels, (i) licence agreement for right to use its trade name and (ii) Master Franchise Agreement (MFA).During year under consideration, assessee received service fee towards package of services under MFA towards third party reservation, Club Carlson marketing fee, reservation fee etc.. Assessing Officer held that amount received by assessee under MFA would fall into different categories, hence, should be treated either as royalty or FTS. On appeal the Tribunal held that  payment received by assessee included marketing, promotion, reservation and other allied which was ancillary and subsidiary to license fee under MFA could not be treated either as royalty or FTS/FIS. Followed order of earlier year. (AY. 2018-19)