AAR held that payment received by the applicant from the Indian hotel owner for provision of global reservation services  ( “CRS”) would be chargeable to tax in India under S.9(1)(1) read with articles 5 and 7 of the India -Luxemburg DTAA as business income and is attributable to the  applicant’s permanent establishment in India.  In view of this the question whether these payments would be  characterised as “ royalty” or fees for technical services “ becomes wholly academic and is therefore , not considered necessary to be answered . AAR also held that   duty of Authority to look at all aspects of questions set forth to enable it to pronounce ruling on substance of questions posed. Giving Ruling on stream of income without regard to other business operations and streams of income leaving other provisions open for regular assessment.