https://www.taxtmi.com/caselaws?id=77077 Under the India-Singapore tax treaty, service-support payments were not fees for technical services because the assistance did not make available technical knowledge, skill or know-how enabling independent future use by the recipient. Access to software applications and hosted server facilities was not royalty because there was no transfer of copyright or right to exploit the software, only facility-based access for internal use. As the amounts were neither treaty FTS nor royalty and the non-resident had no permanent establishment in India, the receipts were not taxable in India and no withholding obligation arose under section 195. en-us Fri, 06 Aug 2010 00:00:00 +0530 Mon, 31 Dec 2012 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=77077 Under the India-Singapore tax treaty, service-support payments were not fees for technical services because the assistance did not make available technical knowledge, skill or know-how enabling independent future use by the recipient. Access to software applications and hosted server facilities was not royalty because there was no transfer of copyright or right to exploit the software, only facility-based access for internal use. As the amounts were neither treaty FTS nor royalty and the non-resident had no permanent establishment in India, the receipts were not taxable in India and no withholding obligation arose under section 195. Case-Laws Income Tax Fri, 06 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=77077