Tribunal held that consideration received for providing training services to Indian Hotels could not be held to be technical services, nor same could have been characterized as ‘ancillary and subsidiary’ services.( AY.2009 -10)
Renaissance Services BV. v. DIT (IT) (2018) 171 ITD 381 / 171 DTR 30/195 TTJ 1049 (Mum) (Trib.)
S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Training services rendered by assessee to Indian Hotels could not be held to be technical services, nor same could have been characterized as ‘ancillary and subsidiary’ services – DTAA-India- Netherland [ Art .12(5)(a) ]