https://www.taxtmi.com/caselaws?id=413304 Consultancy and architectural fees paid to Singapore-based non-resident entities for a residential project were held not to constitute fees for technical services under Article 12(4) of the India-Singapore DTAA. The services were limited to project-specific architectural, structural and MEP drawings and designs, and the agreements did not show any transfer of technical knowledge, experience, skill, know-how or processes enabling the payer to apply the technology independently in future. As the treaty requirement of "making available" technical knowledge was not satisfied, disallowance under section 40(a)(i) could not be sustained and was deleted. en-us Mon, 04 Oct 2021 00:00:00 +0530 Fri, 08 Oct 2021 08:21:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413304 Consultancy and architectural fees paid to Singapore-based non-resident entities for a residential project were held not to constitute fees for technical services under Article 12(4) of the India-Singapore DTAA. The services were limited to project-specific architectural, structural and MEP drawings and designs, and the agreements did not show any transfer of technical knowledge, experience, skill, know-how or processes enabling the payer to apply the technology independently in future. As the treaty requirement of "making available" technical knowledge was not satisfied, disallowance under section 40(a)(i) could not be sustained and was deleted. Case-Laws Income Tax Mon, 04 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413304