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        Case ID :
        Income Tax

        Whether consideration for ancillary support services connected...

        Income tax treatment of ancillary support services for software licenses under IndiaSingapore DTAA found not to be FTS, relief granted

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Whether consideration for ancillary support services connected to software license distribution constitutes Fee for Technical Services under the IndiaSingapore DTAA. The tribunal found the services were ancillary and subsidiary to software sales, including maintenance and technical support obligations under the parties' licence and partner agreements, and thus not characterisable as FTS or as "make available" independent services; consequence: the assessing officer/TPA/DRP findings treating the receipts as FTS were not justified and were disallowed to that extent.
                                Note: It is a system-generated summary and is for quick reference only.
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