INTER CONTINENTAL HOTELS GROUP (ASIA PACIFIC) PTE LTD.,SINGAPORE vs. ACIT, CIRCLE- 2(1)(1), INTERNATIONAL TAXATION, NEW DELHI
In the result, the appeal of the assessee is allowed
ITA 4524/DEL/2017[2012-13]Status: DisposedITAT Delhi24 Sept 2021AY 2012-13
Bench: Sh. Kul Bharatdr. B. R. R. Kumar(Through Video Conferencing)
For Appellant: Sh. S. K. Agarwal, CAFor Respondent: Sh. Umesh Takyar, Sr. DR
Section 139(1)Section 144C(3)
…n the Act. • The Appellant is taking benefit of India-USA DTAA to import the meaning of Make Available, as the same is not defined under India- Singapore DTAA. However, the same is not permitted in light of following judgement:- ONGC vs. ACIT, Dehradun [2006] 9 SOT 8 (Delhi) (SMC) • From the observation of the services being provided, it is clear that the assessee is providing organizational change management assistance, development of coaching skills, or operational improvement services. It is bringing its own, proprietary methodologies or frameworks to guide the identification of problems and to serve as the ba…
