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ITAT ruled no TDS obligation existed under s.195 for payments made to Singapore-based SCPL for advisory/consultancy services. The tribunal determined SCPL lacked a Permanent Establishment in India, as both the assessee and recipient were non-residents. The payment constituted commission for financial services rather than royalty or technical services under Article 12 of India-Singapore DTAA. Key findings emphasized that temporary residence of a director doesn't establish key management decisions occurred in India. The income accrued outside India, and without a PE, was not assessable as business profit or royalty. The arbitrary 55:45 apportionment between India and Singapore by AO was rejected, upholding CIT(A)'s findings and dismissing revenue's appeal.
ITAT ruled no TDS obligation existed under s.195 for payments made to Singapore-based SCPL for advisory/consultancy services. The tribunal determined SCPL lacked a Permanent Establishment in India, as both the assessee and recipient were non-residents. The payment constituted commission for financial services rather than royalty or technical services under Article 12 of India-Singapore DTAA. Key findings emphasized that temporary residence of a director doesn't establish key management decisions occurred in India. The income accrued outside India, and without a PE, was not assessable as business profit or royalty. The arbitrary 55:45 apportionment between India and Singapore by AO was rejected, upholding CIT(A)'s findings and dismissing revenue's appeal.
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