1. There is no clear specific provision in TDS explaining whether subscripttion paid to hotels falls under any category. However, under the given situation, it can be viewed as a contract between members and 5 start hotel for which subscripttion fee is paid.
2. Once the subscripttion fee is paid hotel legally should provide the necessary services under a contract to the member for which the subscripttion fee is paid.
3. Since subscripttion fee is taxable as income in the hands of 5 start hotel, it surely cannot be excluded from TDS ambit. However, nature of subscripttion fee does not fall under any category other than calling it as a contact, thus sec 194C.
4. TDS @ 2% is to be deducted if the payment exceeds Rs. 1 lakhs during the year.
Please correct me if the above solution have an alternative view.