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ITAT held that management fees paid by an Indian affiliate to a Singapore resident assessee do not constitute Fees for Technical Services under Article 12(4) of the India-Singapore DTAA because the Management Services Agreement was effectively perpetual and services were rendered year-to-year without transfer or "making available" of technical know-how, skill, process or technology; accordingly the AO's addition treating receipts as FTS is deleted. Return filed within extended time precludes levy of interest under s.234A, while interest under s.234B remains mandatory. AO is directed to verify the assessee's contention that no refund was granted and, after verification, recompute the demand payable.
ITAT held that management fees paid by an Indian affiliate to a Singapore resident assessee do not constitute Fees for Technical Services under Article 12(4) of the India-Singapore DTAA because the Management Services Agreement was effectively perpetual and services were rendered year-to-year without transfer or "making available" of technical know-how, skill, process or technology; accordingly the AO's addition treating receipts as FTS is deleted. Return filed within extended time precludes levy of interest under s.234A, while interest under s.234B remains mandatory. AO is directed to verify the assessee's contention that no refund was granted and, after verification, recompute the demand payable.
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