CRM subscription receipts were not treated as fees for technical services under domestic law or the India-Singapore tax treaty

Receipts from customer relationship management (CRM) subscription services are discussed in the context of whether they constitute fees for technical services under the Income-tax Act, 1961 or Article 12(4) of the India-Singapore Double Taxation Avoidance Agreement. The analysis applies the position adopted for earlier assessment years in the same assessee's matter and states that the receipts were not chargeable as fees for technical services. It further records that no substantial question of law arose for consideration, with the receipts therefore treated as outside the relevant fees-for-technical-services provisions.

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Issues: Whether receipts from CRM subscription services constituted fees for technical services taxable under the Income-tax Act, 1961 or Article 12(4) of the India-Singapore Double Taxation Avoidance Agreement.

Analysis: The issue was governed by the decision concerning the earlier assessment years in the assessee's own case. Applying that position, the receipts from CRM services were not chargeable as fees for technical services. No substantial question of law arose for consideration.

Conclusion: The CRM subscription receipts were not taxable as fees for technical services under the Income-tax Act, 1961 or the India-Singapore Double Taxation Avoidance Agreement.

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