IN HIGH COURT OF DELHI AT NEW DELHI ITA 713/2019 COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 Appellant Through: Mr.Ajit Sharma, Sr. Standing Counsel with Ms.Adiba Mujahid, Advocate. versus STARWOOD HOTEL & RESORTS WORLDWIDE INC. ..... Respondent Through: Mr.Shailesh Kumar, Advocate. CORAM: JUSTICE S.MURALIDHAR JUSTICE TALWANT SINGH ORDER 02.08.2019 1. Revenue is in appeal against order dated 18 th December 2018 passed by ITAT in ITA 203/Del/2016 for Assessment Year ( AY ) 2011-12. 2. question urged for consideration is whether centralized services rendered by Assessee would amount to technical services in terms of Section 9 of Income Tax Act, 1961 as well as under Article 12 of India US Double Taxation Avoidance Agreement. 3. Tribunal in impugned order relied upon decision of this Court in Director of Income Tax v. Sheraton International Inc (2009) 178 taxman 84 (Del) which answers question in favour of Assessee and against Revenue. 4. Consequently, no substantial question of law arises. appeal is dismissed. S. MURALIDHAR, J. TALWANT SINGH, J. AUGUST 02, 2019 Commissioner of Income-tax, International Taxation-3 v. Starwood Hotel & Resorts Worldwide Inc