The Tribunal held that the payments received from the Indian hotels pursuant to the agreement were income chargeable to tax in India as fees for technical services. (AY. 2011-12).
Global Hospitality Licensing Co. Sarl v. Dy. CIT (IT (2022) 97 ITR 57 (SN) (Mum.)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-Payment received from Indian from Indian hotels chargeable to tax in India.