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Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exists.
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Regional support-service consideration falls outside royalty treatment under the India-Singapore DTAA and domestic law where the provider merely applies its own expertise and does not transfer a right to use industrial, commercial or scientific experience or impart deployable knowledge. It also does not constitute fees for technical services unless technical knowledge, experience, skill, know-how or processes are made available so the recipient can apply them independently. Continued reliance on the provider indicates that this condition is unmet. Such receipts are business profits and are not taxable in India absent a permanent establishment. TDS credit remains subject to factual verification and grant according to law.
Regional support-service consideration falls outside royalty treatment under the India-Singapore DTAA and domestic law where the provider merely applies its own expertise and does not transfer a right to use industrial, commercial or scientific experience or impart deployable knowledge. It also does not constitute fees for technical services unless technical knowledge, experience, skill, know-how or processes are made available so the recipient can apply them independently. Continued reliance on the provider indicates that this condition is unmet. Such receipts are business profits and are not taxable in India absent a permanent establishment. TDS credit remains subject to factual verification and grant according to law.
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