The Authority for Advance Ruling has ruled in the case of FRHI Hotels & Resorts that based on the degree of exclusive control, discretion and authority exercised by the non-resident company over operations of an Indian hotel could mean that such a hotel constituted a fixed place permanent establishment for the former and its income from operations would be taxable as business profits in India.

Also Read: AAR holds non-compete fee is not taxable under India-UK DTAA

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