https://www.taxtmi.com/caselaws?id=396975 Under the India-Singapore DTAA, receipts for infrastructure data centre services were treated as non-taxable because the customer obtained only standard hosting and support output, not any right to use equipment, software, embedded process or proprietary technology. Management service fees and referral fees were also outside treaty taxation because the services did not make available technical knowledge, skill, know-how or processes to the recipient. The commentary further notes that once the receipts were treated as not taxable in India, TDS credit had to be verified and interest under sections 234A, 234B and 234C required consequential recomputation or deletion, while refund-related matters for assessment year 2012-13 were left for verification. en-us Mon, 20 Jul 2020 00:00:00 +0530 Tue, 05 Nov 2024 14:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396975 Under the India-Singapore DTAA, receipts for infrastructure data centre services were treated as non-taxable because the customer obtained only standard hosting and support output, not any right to use equipment, software, embedded process or proprietary technology. Management service fees and referral fees were also outside treaty taxation because the services did not make available technical knowledge, skill, know-how or processes to the recipient. The commentary further notes that once the receipts were treated as not taxable in India, TDS credit had to be verified and interest under sections 234A, 234B and 234C required consequential recomputation or deletion, while refund-related matters for assessment year 2012-13 were left for verification. Case-Laws Income Tax Mon, 20 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396975