https://www.taxtmi.com/caselaws?id=215831 Where fees for technical services are effectively connected with a permanent establishment in India, Article 12(6) of the India-Singapore DTAA gives way to Article 7, so the receipts are not assessed on a gross basis under Article 12 alone. The assessing authority must examine the business-income treatment under Article 7 after giving the assessee an opportunity of hearing. The issue of taxability of interest income was also restored for fresh adjudication in light of the Tribunal decision relied on by the assessee and in accordance with law. en-us Wed, 27 Jun 2012 00:00:00 +0530 Mon, 21 Jan 2013 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215831 Where fees for technical services are effectively connected with a permanent establishment in India, Article 12(6) of the India-Singapore DTAA gives way to Article 7, so the receipts are not assessed on a gross basis under Article 12 alone. The assessing authority must examine the business-income treatment under Article 7 after giving the assessee an opportunity of hearing. The issue of taxability of interest income was also restored for fresh adjudication in light of the Tribunal decision relied on by the assessee and in accordance with law. Case-Laws Income Tax Wed, 27 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215831