Facts of the Case
- Assessee
Status: The assessee, Sheraton
International Inc., is a company incorporated in the USA and a
non-resident under Indian tax laws. It is engaged in providing worldwide
marketing, publicity, advertisement, and reservation services to hotels.
- Agreements
Executed: The assessee entered into
service agreements with Indian clients, including ITC Ltd (later vested in
ITC Hotels Ltd) for hotels such as Welcomgroup Maurya Sheraton (New
Delhi), Mughal Sheraton (Agra), and Chola Sheraton (Madras). Similar
agreements were executed with Adyar Hotels Ltd for Hotel Park Sheraton
(Madras).
- Consideration
Terms: In terms of the agreement, the
assessee was to receive a fee computed at 3% of room sales in
consideration for its integrated services.
- Past
Tax Treatment: Prior to the India-USA Double
Taxation Avoidance Agreement (DTAA) coming into force on 01.04.1991, the
receipts were taxed as "business income" with tax deducted at
source (TDS) under Section 195(2) on an estimated income of 10%.
Post-DTAA, the Revenue initially accepted the assessee's claim that
receipts were not taxable in India due to the absence of a Permanent
Establishment (PE) and issued a No Objection Certificate (NOC) in 1991.
- Reopening
& Best Judgment: In November 1999, the Revenue
issued notices under Sections 163 and 142 of the Income Tax Act, 1961. Due
to non-compliance, the Assessing Officer (AO) passed a best judgment
assessment. The AO concluded that the services involved making technical
and consultancy services, training, trade mark use, and technical know-how
available, classifying the receipts as "Fee for Included
Services" (FIS) under Article 12(4)(b) of the DTAA and under Section
9 of the Act.
- Appellate
Progression:
- The
Commissioner of Income Tax (Appeals) [CIT(A)] bifurcated the receipts,
holding 75% as taxable "Royalty" under Article 12(3)(a) for
trademarks and reservation networks, while treating the remaining 25% for
marketing/publicity outside India as non-taxable business profits.
- In
parallel years, the AO went further, treating 100% of receipts—including
contributions toward the "Sheraton Club International" (SCI),
"Starwood Preferred Guest", and "Frequent Flyer
Programme" (FFP)—as royalty/FIS.
- The
Income Tax Appellate Tribunal (ITAT) set aside the initial orders and
remanded the matter to ensure taxability was first determined under
Sections 4, 5, and 9 of the Act before looking at the DTAA.
- On
remand, the AO reinstated his 100% taxability view. The CIT(A) upheld the
royalty classification on core services but deleted the addition on SCI
and FFP contributions, characterizing them as commercial/business income
non-taxable in India due to lack of a PE. Both parties filed
cross-appeals before the ITAT.
- The
ITAT ruled entirely in favor of the assessee, prompting the Revenue to
appeal before the High Court under Section 260A.
Sections Involved
- Income
Tax Act, 1961: Section 4 (Charge of Income
Tax), Section 5 (Scope of Total Income), Section 9(1)(i) (Income deemed to
accrue or arise through business connection), Section 9(1)(vi) (Royalty),
Section 9(1)(vii) (Fees for Technical Services), and Section 260A (Appeal
to High Court).
Issues Involved
- Whether
the amounts received by the non-resident assessee from Indian hotels under
the service agreements constitute "Business Profits" under
Article 7 of the India-USA DTAA or are taxable as "Royalty"
and/or "Fee for Included Services" (FIS) under Article 12?
- Whether
the receipts are liable to tax under the domestic charging provisions of
Sections 4, 5, and 9 of the Income Tax Act, 1961?
- Whether
the service agreement executed by the assessee represents a colourable
device designed to escape tax liability in India by camouflaging the use
of trademarks as free of cost?
- Whether
contributions received toward the "Sheraton Club International"
(SCI) and "Frequent Flyer Programme" (FFP) constitute "Fee
for Included Services" under Article 12(4)(a) of the DTAA?
Petitioner’s (Revenue's) Arguments
- Industrial
& Commercial Experience:
The learned counsel argued that the assessee possesses vast specialized
knowledge and experience in the hospitality industry. Imparting this
information constitutes providing industrial, commercial, and scientific
experience, falling within Section 9 of the Act and Article 12 of the
DTAA.
- Technology
Made Available: The synchronization of the
Indian hotels’ computers with the assessee's centralized system via
satellite links constitutes imparting technical knowledge and making
technology available.
- Colourable
Device: The composite payment structured
around room sales was a colourable device used to disguise payments
actually meant for the utilization of the 'Sheraton' trademark, brand
name, and stylized "S" mark, which the agreement falsely claimed
were free of cost.
- Ancillary
Services Covered: Marketing, reservation, and
publicity services, alongside SCI and FFP contributions, were ancillary
and subsidiary to the main right to enjoy the property/information,
thereby satisfying the criteria under Article 12(4)(a) and Article
12(4)(b).
Respondent’s (Assessee's) Arguments
- Business
Profits and Lack of PE: The learned Senior Counsel
submitted that the primary services (marketing, advertising, and
reservation systems) were executed through infrastructure located entirely
outside India. The income generated is purely business income, and since
the assessee lacks a Permanent Establishment (PE) in India, it cannot be
taxed under Article 7 of the DTAA.
- No
Business Connection: The receipts did not accrue or
arise through any domestic business connection, excluding the application
of Section 9(1)(i) of the Act.
- Incidental
Trademark Usage: The permission to use the brand
name and stylized "S" was provided solely to facilitate mutual
business interests and maximize customer acquisition worldwide. It was an
integrated business layout where no independent fee was assigned or payable
for the trademark.
- Regulatory
Clearances & Arm's Length:
The agreements were vetted and approved by various statutory authorities
at arm's length. The Revenue's assertion of a colourable device is based
on mere conjecture without any backing evidence.
- Inapplicability
of FIS: Article 12(4)(b) is inapplicable
because the hospitality services do not "make available" any
technical knowledge, skills, or processes to the Indian hotels to enable
them to function independently.
Court's Findings / Order
- Integrated
Business Arrangement: The High Court upheld the
findings of fact recorded by the ITAT. The primary intent of the agreement
was a mutual effort to enhance hotel bookings through integrated
marketing, worldwide publicity, and global reservation infrastructure. Use
of trademarks, localized computer interfaces, and client loyalty programs
were purely incidental or ancillary to this main objective.
- No
Technology "Made Available":
Relying on the India-USA DTAA Memorandum of Understanding (MoU), the Court
observed that commercial information services requiring high technical
skills for performance do not equal a technical service that "makes
technology available". The hotel industry is distinct from fields
where technology is transferred; the computer interface merely facilitated
reservations and did not transfer technical know-how.
- Rejection
of "Colourable Device" Allegation:
The Court confirmed that the Revenue failed to produce any evidence
proving the transaction was a sham or a camouflage. The parties operated
at arm’s length, and necessary regulatory compliances were historically
satisfied.
- Absence
of Question on Perversity:
The High Court, citing the Supreme Court judgment in K. Ravindranathan
Nair vs. CIT, noted that the Tribunal is the final fact-finding
authority. Since the Revenue's appeal did not explicitly propose a
question challenging the ITAT’s findings as perverse, the High Court was
legally bound to accept those facts.
- Conclusion:
The receipts form part of the assessee's "Business Profits". In
the absence of a Permanent Establishment in India, the income cannot be
taxed under Article 7 of the India-USA DTAA. The appeals filed by the
Revenue were dismissed as no substantial question of law arose.
Important Clarification
- Upon subsequent applications filed by the Revenue (CM Nos. 6571/2009 and allied applications), the Bench clarified that Proposed Questions of Law (G) and (H)—pertaining to the non-levy of interest under Section 234B when payments are subject to TDS—were not pressed by the Revenue's counsel during the original hearing exclusively because the underlying tax liability was computed as nil.
Link to download the order –
https://delhihighcourt.nic.in/app/case_number_pdf/2009:DHC:9136-DB/BDA30012009ITA10332007_172221.pdf
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