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The ITAT affirmed that amounts paid for borrowed services do not constitute fees for technical services (FTS) under Article 12 of the India-Singapore DTAA for AY 2020-21 and AY 2021-22. Relying on a Co-ordinate Bench decision in the assessee's own earlier years and noting the Departmental Representative's failure to controvert identical facts, the Tribunal concluded such receipts are not taxable as income deemed to accrue or arise in India under the DTAA. The appeal was allowed in favour of the assessee and decided against the revenue, with relief limited to the specified assessment years.
The ITAT affirmed that amounts paid for borrowed services do not constitute fees for technical services (FTS) under Article 12 of the India-Singapore DTAA for AY 2020-21 and AY 2021-22. Relying on a Co-ordinate Bench decision in the assessee's own earlier years and noting the Departmental Representative's failure to controvert identical facts, the Tribunal concluded such receipts are not taxable as income deemed to accrue or arise in India under the DTAA. The appeal was allowed in favour of the assessee and decided against the revenue, with relief limited to the specified assessment years.
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