https://www.taxtmi.com/caselaws?id=63786 Under the India-Singapore DTAA, Article 7 could not by itself tax the foreign consultant's receipt merely because it lacked a permanent establishment in India; the relevant enquiry had to shift to the specific article on fees for technical services. The feasibility and bankable project report was treated as technical services because it conveyed technical knowledge, experience, skill and know-how by covering project, market, financial, operational and risk factors for presentation to financiers. As a result, the payment fell within Article 12(4)(b), attracted tax in India and required withholding at source under the treaty framework. en-us Wed, 22 Jan 2003 00:00:00 +0530 Tue, 01 Feb 2011 18:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63786 Under the India-Singapore DTAA, Article 7 could not by itself tax the foreign consultant's receipt merely because it lacked a permanent establishment in India; the relevant enquiry had to shift to the specific article on fees for technical services. The feasibility and bankable project report was treated as technical services because it conveyed technical knowledge, experience, skill and know-how by covering project, market, financial, operational and risk factors for presentation to financiers. As a result, the payment fell within Article 12(4)(b), attracted tax in India and required withholding at source under the treaty framework. Case-Laws Income Tax Wed, 22 Jan 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63786