Renaissance Services Bv, Mumbai vs Ddit (It) 2(1), Mumbai on 9 August, 2019
In our view this decision in the case of
Marriott International Inc Vs DDIT (supra) based on different set of facts.
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1 - 8 of 8 (0.42 seconds)Renaissance Services Bv, Mumbai vs Ddit (It) 2(1), Mumbai on 24 February, 2022
Global Hospitality Licensing Sarl, ... vs Dcit (It) Range - 2 (3)(2), Mumbai on 28 March, 2023
Harward Medical International Usa, ... vs Department Of Income Tax
In page 15A to 15D of the CIT(A)'s order a summary of the activities
undertaken by the assessee for WHL have been given. A perusal of the same
shows that the consideration received by the assessee cannot be said to be
royalty as they were not a payment for use of order, the right to use any copy
right, trademark or industrial, commercial or scientific experience. Similarly
the assessee did not make available any technical knowledge, experience,
skill knowhow or process. The decision of the Delhi Bench of the ITAT in the
case of Sheraton International Inc.(supra) supports the plea of the assessee
that where the agreement between the parties provides that there was no
economic consideration for right to use the name it cannot be said that any
payment can be called royalty.
Six Continents Hotels, Inc, Mumbai vs Dcit (It) - 4(2)(1), Mumbai on 8 February, 2024
Therefore, in view of the above, we find no merits in the reliance
placed by the lower authorities on the aforesaid decision in Marriott
International Inc (supra).
M/S Six Continents Hotels Inc., Gurgaon vs Dy Cit Circle 4 (2)(1)(Inter National ... on 8 February, 2024
Therefore, in view of the above, we find no merits in the reliance
placed by the lower authorities on the aforesaid decision in Marriott
International Inc (supra).
Six Continents Hotels Inc., Gurgaon vs Dy Cit Circle- 4 (2)(1), Mumbai on 8 February, 2024
Therefore, in view of the above, we find no merits in the reliance
placed by the lower authorities on the aforesaid decision in Marriott
International Inc (supra).
M/S Six Continents Hotels Inc., Gurgaon vs The Dy Cit Circle-4(2)(1), ... on 8 February, 2024
Therefore, in view of the above, we find no merits in the reliance
placed by the lower authorities on the aforesaid decision in Marriott
International Inc (supra).
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