https://www.taxtmi.com/caselaws?id=353934 Administrative support receipts under the India-Singapore tax treaty were examined against the make available test for fees for technical services. Because the record contained only limited correspondence and billing material, and did not clearly establish how the services were rendered or whether technical knowledge, skill or experience was made available, the taxability question was sent back for fresh factual examination. Interest under section 234B was held not chargeable in respect of non-resident income subject to tax withholding at source, as advance tax liability did not arise. The grossing-up adjustment was also remitted because it depended on the final determination of the underlying taxability of the receipts. en-us Mon, 08 Jan 2018 00:00:00 +0530 Mon, 15 Jan 2018 07:43:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=353934 Administrative support receipts under the India-Singapore tax treaty were examined against the make available test for fees for technical services. Because the record contained only limited correspondence and billing material, and did not clearly establish how the services were rendered or whether technical knowledge, skill or experience was made available, the taxability question was sent back for fresh factual examination. Interest under section 234B was held not chargeable in respect of non-resident income subject to tax withholding at source, as advance tax liability did not arise. The grossing-up adjustment was also remitted because it depended on the final determination of the underlying taxability of the receipts. Case-Laws Income Tax Mon, 08 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=353934