https://www.taxtmi.com/caselaws?id=251966 Payments for distribution, management and logistic services were not taxable as fees for technical services under the India-Singapore DTAA because the decisive test is whether the service provider made available technical knowledge, experience or skill to the recipient. On the Tribunal's findings, the services were rendered from outside India, the provider had no permanent establishment in India, and no technical knowledge or technology was transmitted to the assessee. The receipts therefore fell outside the treaty concept of fees for technical services and were not taxable as business income in the absence of a permanent establishment. en-us Mon, 02 Jun 2014 00:00:00 +0530 Thu, 19 Feb 2015 11:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251966 Payments for distribution, management and logistic services were not taxable as fees for technical services under the India-Singapore DTAA because the decisive test is whether the service provider made available technical knowledge, experience or skill to the recipient. On the Tribunal's findings, the services were rendered from outside India, the provider had no permanent establishment in India, and no technical knowledge or technology was transmitted to the assessee. The receipts therefore fell outside the treaty concept of fees for technical services and were not taxable as business income in the absence of a permanent establishment. Case-Laws Income Tax Mon, 02 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251966