https://www.taxtmi.com/caselaws?id=151576 Under the India-Singapore treaty, logistics services are not fees for technical services unless they "make available" technical knowledge, skill, know-how or processes so the recipient can apply them independently. Mere performance of technical or logistics work is insufficient where no enduring technical ability is transferred. On the stated facts, the payer did not acquire such usable technical knowledge, and the Singapore recipient had no permanent establishment in India; the receipts were therefore outside article 12(4) and article 7, and no tax was deductible at source under section 195. en-us Fri, 21 Aug 2009 00:00:00 +0530 Sat, 02 Dec 2023 12:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=151576 Under the India-Singapore treaty, logistics services are not fees for technical services unless they "make available" technical knowledge, skill, know-how or processes so the recipient can apply them independently. Mere performance of technical or logistics work is insufficient where no enduring technical ability is transferred. On the stated facts, the payer did not acquire such usable technical knowledge, and the Singapore recipient had no permanent establishment in India; the receipts were therefore outside article 12(4) and article 7, and no tax was deductible at source under section 195. Case-Laws Income Tax Fri, 21 Aug 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=151576