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The ITAT examined the taxability of management support services income under the India-Singapore DTAA's Article 12. Referencing a precedent in Michael Page International Recruitment Private Limited, the tribunal determined that the income from management support services does not qualify as Fees for Technical Services (FTS). Consequently, the tribunal upheld the assessee's plea, deleting the contested income addition and ruling in favor of the assessee, thereby establishing that such services do not attract taxation under the specified treaty provisions.
The ITAT examined the taxability of management support services income under the India-Singapore DTAA's Article 12. Referencing a precedent in Michael Page International Recruitment Private Limited, the tribunal determined that the income from management support services does not qualify as Fees for Technical Services (FTS). Consequently, the tribunal upheld the assessee's plea, deleting the contested income addition and ruling in favor of the assessee, thereby establishing that such services do not attract taxation under the specified treaty provisions.
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