https://www.taxtmi.com/caselaws?id=383613 Management support receipts were treated as business profit rather than fees for technical services because the services did not make available technical knowledge, experience, skill, knowhow or process to the recipient under the India-Singapore tax treaty. Taxability in India then depended on whether the Singapore recipient had a permanent establishment; the Tribunal required verification of the employee-stay claim before deciding that point. Interest under section 234B was held not leviable on the non-resident, following the settled rule that advance tax liability does not arise where tax is deductible at source by the payer. en-us Mon, 22 Apr 2019 00:00:00 +0530 Fri, 26 Jul 2019 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383613 Management support receipts were treated as business profit rather than fees for technical services because the services did not make available technical knowledge, experience, skill, knowhow or process to the recipient under the India-Singapore tax treaty. Taxability in India then depended on whether the Singapore recipient had a permanent establishment; the Tribunal required verification of the employee-stay claim before deciding that point. Interest under section 234B was held not leviable on the non-resident, following the settled rule that advance tax liability does not arise where tax is deductible at source by the payer. Case-Laws Income Tax Mon, 22 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383613