Soul of Japan on a Plate
The dessert highlight? A Peanut Butter Tart that was not only indulgent but also healthy. The chef explained that the tart's base was made from buckwheat — making it gluten-free, fibre-rich, and full of essential minerals.
The experience was rounded off with a drinks menu that included standouts like the Chili Negroni — a bold twist on the classic, where chilli-infused gin blended with Aperol and house-made aromatic vermouth for a perfectly balanced, spicy sip.
Reflecting on his culinary journey, Chef Vikramjit shared, 'It's been humbling — from peeling vegetables to leading kitchens and being recognised by legends like Marco Pierre White and Sanjeev Kapoor. The journey has always been about learning, evolving, and staying honest to the craft.'
He also reminisced about his most cherished food memory, 'Eating freshly steamed momos with my family in the hills as a child. That memory still defines my understanding of comfort, warmth, and flavour.'
When asked if he plans to open a restaurant in Hyderabad, he smiled and said, 'Hyatt as a brand is deeply committed to crafting unique culinary experiences across its properties, and it's exciting to see Park Hyatt Hyderabad pushing boundaries with Asian cuisine. While I'm currently focused on building something meaningful with Hyatt India, collaborations like this pop-up allow us to bring a taste of that journey to new cities.'
For Chef Vikramjit, the kitchen is his sanctuary, 'What I love most is creating a melting pot. When you cook around the world and explore cultures, you notice beautiful similarities. Creating a natural intersection of different culinary traditions, while staying true to each, is where I find joy. It's where everything comes together — flavour, colour, emotion, and story. It's my meditative moment before the guest takes the first bite.'
And that's exactly what the experience was — an elevated, multi-sensory journey where every dish told a story, blending authenticity with bold creativity.
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Hindustan Times
06-08-2025
- Hindustan Times
An All-Inclusive Resort for $900 a Night? I Put One to the Test
PLAYA DEL CARMEN, Mexico—The phone in my oceanview suite rang at 8:37 a.m. 'Good morning, ma'am, this is Alejandro to tell you your service is in the secret box.' The eggs Benedict, bacon and french toast I ordered were waiting in my private delivery closet, no hefty room-service bill to sign. The night before, a butler drew a bubble bath in the soaking tub on the balcony while I was dining at a French restaurant sans pricey check. It was my first taste of the all-inclusive resort life on steroids. Big U.S. hotel brands like Hyatt and Marriott are betting that affluent travelers will consider these one-price-covers-it-all vacations—often derided as cruises on land—if they promise better food, drinks, service, rooms and pools. The upgrades don't come cheap. Room rates can top $1,000 for two at top-of-the-line resorts. Marriott just opened its first all-inclusive W resort, in Punta Cana in the Dominican Republic, following last year's debut of its first Marriott-branded, all-inclusive in Cancún. There are even preliminary plans for an all-inclusive Ritz-Carlton. Hyatt is betting big on luxury all-inclusive resorts including Impression Moxché by Secrets in Playa del Carmen, Mexico. Hyatt has become a major all-inclusive player in Mexico and the Caribbean thanks to big acquisitions, and now has 10 all-inclusive brands including Hyatt Ziva, Hyatt Zilara, Secrets and Breathless. The company opened its first all-inclusive in Aruba—Secrets Baby Beach—this summer. Of course, all-inclusive can mean many things, as I discovered during my cheapo $129 all-inclusive stay in Las Vegas in June. To size up this crop of newer entrants, I booked a short all-inclusive adventure in Mexico in late July. Tough duty, I know. But it was so hot and humid I didn't need the clothes steamer in the room. The wrinkles just melted away. I spent one night at the Marriott All-Inclusive Cancun ($500 for one, $650 for two) and two nights at Hyatt's top of the line Impression Moxché by Secrets an hour south of Cancún in Playa del Carmen ($900 per night for up to two people), home of the secret box and butler and Hyatt's investor day in 2023. Marriott was all ages; the Hyatt was adults only. Neither resort knew I was a reporter. The real deal All-inclusives and Cancún aren't usually my jam, but I love a sprawling beach resort for a laid-back vacation. Both resorts I tried included, well, just about everything promised. Multiple restaurant options, unlimited drinks, nonstop activities that weren't all cheesy (well, there was bingo and a casino night), spas and, at Secrets, pools galore, including infinity pools with great views and free cabanas. Marriott opened its first branded all-inclusive in Cancún last year. Guests have their choice of beach or infinity pool. The rooms were plush (at Secrets it was the biggest suite I've stayed in) with great views. I listened to pop music covers from my patio and sipped espresso martinis, frozen and straight up. I even danced at a pharmacy-turned-speakeasy at Secrets (before the youngsters arrived.) And I didn't spend a cent extra at either place, except for tips. In other words, these places are the real deal. And they offer real value if you want an upscale getaway where the toughest decision you make is where to eat and sunbathe, and you hate checking out with pages and pages of charges. (Looking at you, resorts with overpriced kids' smoothies, $20 frozen cocktails and $30 poolside burgers, fries extra.) At my swank Secrets tower, there was a nonstop spread of goodies at the lobby bar throughout the day if you wanted a pre-meal snack. On the menu: chia pudding, green juice and pastries in the morning, a charcuterie plate and irresistible chocolate bark later on. My favorite meal of the trip, possibly because of the beachside setting at sunset, was lobster risotto at the Mediterranean restaurant at the Marriott. At the Hyatt, I ate almost exclusively at the two restaurants reserved for guests staying in the high-end Impression tower. (It's nearly double the cost of staying in the other tower and also includes the butler, a private pool with complimentary cabanas and a signature spritz.) I ate my weight in homemade chips, guacamole and pico de gallo and enjoyed the shrimp ceviche and mini lobster roll. A quibble or two Not that there weren't upsells, though nothing like I've seen on cruise ships. The Marriott's lobby had an 'elevated experiences information desk.' It offered romantic dinners on the beach and mescal tastings. Hyatt offered a seven-course tasting menu at its AAA Five Diamond restaurant for an extra $75 per person unless you were staying more than five days. Dreamy views from my oceanview suite at Impression Moxché by Secrets in Playa Del Carmen. But there were more than enough complimentary choices for every meal and snack plus free room service. There's a 24-hour outlet at the Marriott that doubles as the morning coffee and pastry shop and nighttime pizza go-to. There were things to critique. The daytime butler at Secrets wasn't at our beck and call all day except through WhatsApp and started at 9 a.m. not 7 as advertised. (Another guest from Illinois had the opposite experience; she said her butler was always around.) The fully stocked minibars weren't all they're cracked up to be. Just a few cans of beer, soda and grocery-store snacks. The morning grab-and-go spread in the lobby at Impression Moxché; a beachside filet and lobster risotto at Marriott All-Inclusive Cancun. I was particularly disappointed in the wine list at Impression by Secrets, a hotel-within-a-hotel that is ranked as high as Park Hyatt in Hyatt's loyalty program hierarchy. I opened the lunch menu on the first day to find every wine had a price tag. The upcharges weren't exorbitant but it felt like nickel and diming. What was free: house wine like you would find at your neighborhood happy hour. The Sauvignon Blanc from Chile wasn't bad, just not the quality I expected—and I'm no wine snob. These are, admittedly, first-world problems. And what I'll really remember are the rooms, the views, the pools and service, especially at Secrets. I don't know what kind of training employees receive, but almost every request was met with 'my pleasure,' 'a pleasure' or 'with pleasure.' Lost? An employee doesn't just talk but walks you there. They remember your name, even on a short stay. The best part: no sticker shock at check out. I got more than my (company's) money's worth. Call me an all-inclusive convert—with the right amount of pampering. Write to Dawn Gilbertson at An All-Inclusive Resort for $900 a Night? I Put One to the Test An All-Inclusive Resort for $900 a Night? I Put One to the Test An All-Inclusive Resort for $900 a Night? I Put One to the Test
Hindustan Times
25-07-2025
- Hindustan Times
Operational control enough to tax foreign firms in India, says SC
The Supreme Court on Thursday held that a multinational company may be taxed in India so long as it exercises significant operational control over such premises, even if it has no employees staying here for a period longer than the threshold typically used to assess whether the company is a so-called Permanent Establishment. Operational control enough to tax foreign firms in India, says SC The ruling , which has significant implications for MNCs operating in India, came as a setback to Dubai-based Hyatt International Southwest Asia Ltd, which had challenged its tax liability in India for advisory and management services rendered to Hyatt hotels across the country between 2009 and 2018. A bench of justices JB Pardiwala and R Mahadevan affirmed a 2023 Delhi High Court judgment that recognised Hyatt's presence in India as a Permanent Establishment (PE) under Article 5(1) of the India-UAE Double Taxation Avoidance Agreement (DTAA). The court concluded that Hyatt's active control over the day-to-day hotel operations in India through long-standing agreements established a fixed place PE, making it liable to pay tax in India. Typically, only branch offices, factories, mines etc are considered PEs, although there is also a stipulation related to the time employees spend in India. At the centre of this case was a Services and Operating Services Agreement (SOSA) signed by Hyatt with hotel owners in India, under which the Dubai-based entity provided hotel advisory and consultancy services. Hyatt contended that it operated solely from Dubai, was not obliged to station staff in India, and only permitted occasional visits by its personnel to Indian hotels. It further argued that the SOSA contained no clause allowing it to conduct business from within the hotels, nor did it maintain any office or branch in India. But the top court rejected these submissions, holding that the 'disposal test' for identifying a PE did not require exclusive possession or formal rights over premises, but a fact-specific inquiry into the foreign enterprise's ability to conduct core business functions from the premises. 'The appellant's contention that the absence of an exclusive or designated physical space within the hotel precludes the existence of a PE, is misconceived, said the court, relying on its earlier precedent in Formula One World Championship Ltd ()2017. 'Temporary or shared use of space is sufficient, provided business is carried on through that space,' it added. In this case, the bench found that Hyatt exercised 'pervasive and enforceable control' over the hotel's strategic, operational, and financial aspects. This included the authority to appoint and supervise key personnel, implement HR and procurement policies, control pricing and branding, operate bank accounts, and assign staff to the hotel without the owner's approval. 'These rights go well beyond mere consultancy and indicate that the appellant was an active participant in the core operational activities of the hotel,' said the court, noting that Hyatt's control extended to everyday affairs and not just high-level decisions. Amit Baid, Head of Tax at BTG Advaya law firm, said that the ruling could set a precedent for PE determinations in cases involving frequent employee travel to India. 'The judgment provides a clear conceptual framework for determining PE thresholds -- frequent, regular visits by employees, rather than the duration of individual stays, is the key factor. Once continuity of business presence is established, the return or rotation of individuals becomes irrelevant; and operational control, oversight, and income linked to core functions establish a commercial nexus necessary for a PE,' Baid added. The judgment meanwhile stressed that the 20-year duration of the agreements, combined with continuous and structured involvement of Hyatt's executives in India, satisfied the three-pronged test of stability, productivity, and dependence that governs the recognition of a PE. Further, the court ruled that even though no single Hyatt employee exceeded the 9-month threshold under Article 5(2)(i) of the DTAA, the aggregate and continuous presence of various employees, verified through travel logs and operational duties, fulfilled the requirement of a PE. The court clarified that the legal form of presence is secondary to the economic substance of business functions being carried out in India. 'The appellant's ability to enforce compliance, oversee operations, and derive profit-linked fees from the hotel's earnings demonstrates a clear and continuous commercial nexus and control with the hotel's core functions,' the bench said, calling the hotel premises the 'situs of the appellant's primary business operations.' Importantly, the Supreme Court clarified that under the India–UAE Direct Taxation Avoidance Agreement, the lack of a specific article allowing taxation of Fees for Technical Services (FTS) would not override the existence of a PE under Article 5(1), particularly where core business functions are carried out through a fixed place.
Time of India
24-07-2025
- Time of India
SC says Hyatt's India operations are taxable under PE norms
In a ruling that has significant implications for multinational companies operating in India, the Supreme Court Thursday held that UAE-headquartered Hyatt International Southwest Asia , which provides hotel consultancy and advisory services in India as part of its business operations, has a fixed place Permanent Establishment (PE) in India for tax purposes. Upholding a Delhi High Court order that ruled against the hotel company, a bench comprising Justices J.B. Pardiwala and R. Mahadevan dismissed various the appeals by Hyatt International Southwest Asia Ltd, while affirming the findings of the HC that Hyatt had a fixed place PE in India within the meaning of Article 5(1) of the DTAA, and that, the income received under the strategic oversight services agreements (SOSA) is attributable to such PE and is, therefore, taxable in India. Explore courses from Top Institutes in Please select course: Select a Course Category Public Policy Leadership PGDM Finance Design Thinking Cybersecurity CXO Technology Digital Marketing Data Science Artificial Intelligence Healthcare MBA Project Management Operations Management Data Science Degree Management Others others healthcare Product Management MCA Skills you'll gain: Duration: 12 Months IIM Calcutta Executive Programme in Public Policy and Management Starts on undefined Get Details Skills you'll gain: Economics for Public Policy Making Quantitative Techniques Public & Project Finance Law, Health & Urban Development Policy Duration: 12 Months IIM Kozhikode Professional Certificate Programme in Public Policy Management Starts on Mar 3, 2024 Get Details The top court said that was undisputed that Hyatt's executives and employees paid frequent and regular visits to India to oversee operations and implement SOSA. 'The finding of the assessing officer, based on travel logs and job functions, establish continuous and coordinated engagement, even though no single individual exceeded the 9-month stay threshold,' according to SC Under Article 5(2)(i) of the agreement between the government of India and the United Arab Emirates for avoidance of double taxation (DTAA) Under Article 5(2)(i) of the DTAA, the relevant consideration is the continuity of business presence in aggregate – not the length of stay of each individual employee. Once it is found that there is continuity in the business operations, the intermittent presence or return of a particular employee becomes immaterial and insignificant in determining the existence of a PE, Justice Mahadevan, writing for the bench stated, adding the HC was correct in concluding that Hyatt's role was not confined to high-level decision making, but extended to substantial operational control and implementation. The Dubai-based company's ability to enforce compliance, oversee operations, and derive profit-linked fee from the hotel's earnings, demonstrate a clear and continuous commercial nexus, and control with the hotel's core functions, the judgment said, adding that this nexus satisfied the condition necessary for the constitution of a fixed place of PE under Article 5(1) of the India – UAE DTAA. The top court further said that 'the extent of control, strategic decision-making, and influence exercised by the appellant clearly establish that business was carried on through the hotel premises, satisfying the conditions under Article 5(1)…the hotel itself was the situs of the appellant's primary business operations, carried out under its direct supervision and aligned with its commercial interests.' Welcoming the ruling, Amit Baid of BTG Advaya said that "the judgment provides a clear conceptual framework for determining PE thresholds—frequent, regular visits by employees, rather than the duration of individual stays, is the key factor; once continuity of business presence is established, the return or rotation of individuals becomes irrelevant; and operational control, oversight, and income linked to core functions establish a commercial nexus necessary for a PE. The ruling could set a precedent for PE determinations in cases involving frequent employee travel to India." The judgement establishes that substantive operational involvement, such as orchestrating policies, directly overseeing operations, and controlling implementation, will be closely scrutinised when determining the existence of a fixed place PE in India, said Varun Gakhar, Research Associate at Janssen-Sanghavi & Associates. 'In essence, oversight that crosses into operational control may trigger domestic tax exposure under Indian tax treaties. This judgement will have to be analysed closely by multinationals, as determining whether a PE exists is a very fact- and circumstance-specific question,' he added. In 2008, Hyatt had entered into two strategic oversight services agreements with Asian Hotels Ltd. One was in respect of hotel Hyatt Regency, Delhi owned by Asian Hotels, and the other pertained to a hotel in Mumbai. Under the terms of the agreement, Hyatt agreed to provide strategic planning services and "know-how" to ensure that Hyatt Regency was developed and operated as an efficient and a high quality international full-service hotel. Asian Hotels was thereafter reorganised and its name was subsequently changed to Asian Hotels (North) Ltd., which continued to own Hyatt Regency. For the Assessment Year 2009-10, Hyatt filed its return of income declaring 'Nil' income and claiming a refund of around Rs 88 lakh. The Assessing Officer had passed assessment orders for 2009-18, holding that Hyatt's activities constituted a business connection under Section 9(1)(i) of the Income Tax Act; a PE under Article 5 of the DTAA; royalties and fees for technical services under both the Income Tax Act and DTAA. However, Hyatt asserted that its income was not taxable under the Act as there was no specific Article under the DTAA for taxing Fees for Technical Services. It further stated that it did not have any fixed place of business, office, or branch in India, and that the presence of its employees in India during the relevant previous year did not exceed the nine-month threshold under Article 5(2) of the DTAA. Therefore, the appellant claimed that it did not have a PE in India and that its business income was not taxable under Article 7 of the DTAA. The Income Tax Appellate Tribunal (ITAT) in December 2019 and then the HC rejected Hyatt's contention that it did not have a PE in India.
