https://www.taxtmi.com/caselaws?id=327186 The Tribunal upheld the CIT(A)'s decision that payments to TTPL were not taxable as "fee for technical services" under the DTAA between India and Singapore. It was found that the services did not meet the "make available" criterion required under the DTAA, as they did not provide technical knowledge enabling independent application. Therefore, the assessee was not required to deduct tax at source under section 195 of the Income-tax Act, and the Revenue's appeal was dismissed. en-us Wed, 30 Mar 2016 00:00:00 +0530 Mon, 02 May 2016 18:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327186 The Tribunal upheld the CIT(A)'s decision that payments to TTPL were not taxable as "fee for technical services" under the DTAA between India and Singapore. It was found that the services did not meet the "make available" criterion required under the DTAA, as they did not provide technical knowledge enabling independent application. Therefore, the assessee was not required to deduct tax at source under section 195 of the Income-tax Act, and the Revenue's appeal was dismissed. Case-Laws Income Tax Wed, 30 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327186