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The HC upheld the AO's findings, rejecting the Revenue's appeal as the issues raised did not stem from the original assessment order. The court affirmed that payments made by the assessee to an overseas associate enterprise for conducting general training workshops did not constitute fees for technical services under Article 12 of the India-Singapore DTAA. The court emphasized that definitions under the DTAA govern such terms, not domestic tax law, and general employee training lacks the transfer of technical knowledge or skill necessary to qualify as technical services. Consequently, the addition for payments to seconded employees was not warranted, and the treatment of free-of-cost assets and related depreciation in computing operating profit margin under transfer pricing provisions was upheld. No substantial question of law arose, and the impugned order stood confirmed.
The HC upheld the AO's findings, rejecting the Revenue's appeal as the issues raised did not stem from the original assessment order. The court affirmed that payments made by the assessee to an overseas associate enterprise for conducting general training workshops did not constitute fees for technical services under Article 12 of the India-Singapore DTAA. The court emphasized that definitions under the DTAA govern such terms, not domestic tax law, and general employee training lacks the transfer of technical knowledge or skill necessary to qualify as technical services. Consequently, the addition for payments to seconded employees was not warranted, and the treatment of free-of-cost assets and related depreciation in computing operating profit margin under transfer pricing provisions was upheld. No substantial question of law arose, and the impugned order stood confirmed.
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