https://www.taxtmi.com/caselaws?id=210083 The Tribunal allowed the appeals, determining that payments for data processing services were classified as "Business Profits" under the Double Taxation Avoidance Agreement (DTAA) between India and Singapore, not as "Royalty." As the service provider did not have a Permanent Establishment in India, the payments were not taxable in India. The decision highlighted the distinction between payments for services and those for intellectual property, emphasizing the specific nature of the services provided. en-us Wed, 11 May 2011 00:00:00 +0530 Fri, 26 Oct 2018 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210083 The Tribunal allowed the appeals, determining that payments for data processing services were classified as "Business Profits" under the Double Taxation Avoidance Agreement (DTAA) between India and Singapore, not as "Royalty." As the service provider did not have a Permanent Establishment in India, the payments were not taxable in India. The decision highlighted the distinction between payments for services and those for intellectual property, emphasizing the specific nature of the services provided. Case-Laws Income Tax Wed, 11 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210083