Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
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TDS u/s 195 - remittance towards ‘group cost recharge’ to its associated enterprise(AE) in Singapore - impugned services rendered for which the payment was collected by Singapore entity through cost recharge mechanism is not assessable as ‘fee for technical services’ under Article 12 of India – Singapore DTAA when it does not ‘make available’ any technical knowledge, skill, experience, etc. - no legal obligation to deduct withholding tax on the impugned remittance - AT
TDS u/s 195 - remittance towards ‘group cost recharge’ to its associated enterprise(AE) in Singapore - impugned services rendered for which the payment was collected by Singapore entity through cost recharge mechanism is not assessable as ‘fee for technical services’ under Article 12 of India – Singapore DTAA when it does not ‘make available’ any technical knowledge, skill, experience, etc. - no legal obligation to deduct withholding tax on the impugned remittance - AT
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