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Management and business support service fees paid to an Indian subsidiary were held not taxable as fees for technical services under the India-Singapore DTAA because the receipts did not satisfy the treaty's make available requirement in Article 12(4)(b). The treaty position was applied over the broader domestic definition of fees for technical services, and the addition was deleted. The Tribunal also relied on the unchanged service arrangement and the consistent view taken in earlier years in the same assessee's case, leaving the remaining grounds academic.
Management and business support service fees paid to an Indian subsidiary were held not taxable as fees for technical services under the India-Singapore DTAA because the receipts did not satisfy the treaty's make available requirement in Article 12(4)(b). The treaty position was applied over the broader domestic definition of fees for technical services, and the addition was deleted. The Tribunal also relied on the unchanged service arrangement and the consistent view taken in earlier years in the same assessee's case, leaving the remaining grounds academic.
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