https://www.taxtmi.com/caselaws?id=390081 Payments for bandwidth services to a Singapore recipient were not royalty under section 9(1)(vi) or Article 12 of the India-Singapore DTAA because the payer received only the service, not access to equipment or a secret process, and the domestic-law explanations could not expand the treaty meaning through Article 3(2). Payments for operations and maintenance services were not fees for technical services under section 9(1)(vii) or the treaty because no technical knowledge, skill, know-how or process was made available to the payer. The additions were therefore unsustainable, and the appellate relief remained undisturbed. en-us Mon, 25 Nov 2019 00:00:00 +0530 Mon, 23 Dec 2019 13:42:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390081 Payments for bandwidth services to a Singapore recipient were not royalty under section 9(1)(vi) or Article 12 of the India-Singapore DTAA because the payer received only the service, not access to equipment or a secret process, and the domestic-law explanations could not expand the treaty meaning through Article 3(2). Payments for operations and maintenance services were not fees for technical services under section 9(1)(vii) or the treaty because no technical knowledge, skill, know-how or process was made available to the payer. The additions were therefore unsustainable, and the appellate relief remained undisturbed. Case-Laws Income Tax Mon, 25 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390081