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The ITAT ruled in favor of the taxpayer, determining that fabrication charges received could not be treated as "fees for technical services" under Article 12(4)(a) of the India-Singapore DTAA. The Tribunal noted this was a recurring issue for the taxpayer across assessment years 2015-16 to 2020-21, with consistent favorable rulings. The ITAT rejected the Assessing Officer's application of 10% tax on these charges, holding that the receipts toward fabrication of bushings did not constitute fees for technical services under the treaty, as no royalty under Article 12(3) of the India-Singapore DTAA was received by the taxpayer.
The ITAT ruled in favor of the taxpayer, determining that fabrication charges received could not be treated as "fees for technical services" under Article 12(4)(a) of the India-Singapore DTAA. The Tribunal noted this was a recurring issue for the taxpayer across assessment years 2015-16 to 2020-21, with consistent favorable rulings. The ITAT rejected the Assessing Officer's application of 10% tax on these charges, holding that the receipts toward fabrication of bushings did not constitute fees for technical services under the treaty, as no royalty under Article 12(3) of the India-Singapore DTAA was received by the taxpayer.
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