IN THE ITAT DELHI BENCH
G.S. PANNU, PRESIDENT & SAKTIJIT DEY, J.M.
Shangri-La International Hotel Management Pte. Ltd. v. ACIT
ITA Nos. 2254 & 2255/Del/2022
28 February, 2023
Department by: S.K. Agarwal, CA
Assessee by: Gangadhar Panda, CIT- DR
Saktijit Dey, J.M.
Captioned appeals filed by the assessee arise out of final assessment orders passed under section 143(3) read with section 144C(13) of the Income-Tax Act, 1961 pertaining to assessment years 2018-19 and 2019-20.
2. The first common dispute raised in both the appeals relates to addition of marketing receipts, frequent guest program receipts, general advertising, coordination fund contribution and reservation fees etc. as Fee For Technical Services (FTS) under article 12 of the India-Singapore Double Taxation Avoidance Agreement (DTAA) and section 9(1)(vii) of the Act.