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Non-resident corporate assessee's receipts for maintenance, support, training services, and additional services relating to software migration held not taxable as Fees for Technical Services (FTS) under India-Singapore DTAA. Services did not make available technical knowledge or skills to recipient on a recurring basis. Assessee had no PE in India, so business receipts not taxable. ITAT allowed assessee's appeal.
Non-resident corporate assessee's receipts for maintenance, support, training services, and additional services relating to software migration held not taxable as Fees for Technical Services (FTS) under India-Singapore DTAA. Services did not make available technical knowledge or skills to recipient on a recurring basis. Assessee had no PE in India, so business receipts not taxable. ITAT allowed assessee's appeal.
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