https://www.taxtmi.com/highlights?id=28958 TDS u/s 195 - remittance towards ‘group cost recharge’ to its associated enterprise(AE) in Singapore - impugned services rendered for which the payment was collected by Singapore entity through cost recharge mechanism is not assessable as ‘fee for technical services’ under Article 12 of India – Singapore DTAA when it does not ‘make available’ any technical knowledge, skill, experience, etc. - no legal obligation to deduct withholding tax on the impugned remittance - AT en-us Thu, 05 May 2016 00:50:04 +0530 Thu, 05 May 2016 00:50:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=28958 TDS u/s 195 - remittance towards ‘group cost recharge’ to its associated enterprise(AE) in Singapore - impugned services rendered for which the payment was collected by Singapore entity through cost recharge mechanism is not assessable as ‘fee for technical services’ under Article 12 of India – Singapore DTAA when it does not ‘make available’ any technical knowledge, skill, experience, etc. - no legal obligation to deduct withholding tax on the impugned remittance - AT Highlights Income Tax Thu, 05 May 2016 00:50:04 +0530 https://www.taxtmi.com/highlights?id=28958