https://www.taxtmi.com/caselaws?id=406330 Under the India-Singapore treaty, receipts for managed services, data centre hosting and related project services were not royalty because the recipient did not obtain any right to use copyright, process, equipment or similar property; the treaty definition controlled and domestic law could not enlarge it. The same receipts were also not fees for technical services because the services did not make available technical knowledge, experience, skill, know-how or processes that the recipient could apply independently. The cost recharge relating to an employee's salary was remitted for fresh factual examination, as the material was insufficient to determine whether any technical knowledge had been made available. The main addition was deleted, with partial relief granted. en-us Tue, 30 Mar 2021 00:00:00 +0530 Thu, 08 Apr 2021 11:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406330 Under the India-Singapore treaty, receipts for managed services, data centre hosting and related project services were not royalty because the recipient did not obtain any right to use copyright, process, equipment or similar property; the treaty definition controlled and domestic law could not enlarge it. The same receipts were also not fees for technical services because the services did not make available technical knowledge, experience, skill, know-how or processes that the recipient could apply independently. The cost recharge relating to an employee's salary was remitted for fresh factual examination, as the material was insufficient to determine whether any technical knowledge had been made available. The main addition was deleted, with partial relief granted. Case-Laws Income Tax Tue, 30 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406330