https://www.taxtmi.com/caselaws?id=432772 Receipts from disaster recovery uplinking and satellite-based telecommunication services were not taxable as royalty because the customers had no possession, control, or right to use the provider's equipment or process; the arrangement was a service contract, and retrospective domestic amendments did not enlarge the treaty definition. Receipts from disaster recovery playout services were not taxable as fees for technical services because the activity did not make available technical knowledge, skill, or know-how, nor was it ancillary or subsidiary in the required sense. On that reasoning, the disputed receipts were treated as non-taxable under the India-Singapore DTAA. en-us Mon, 19 Dec 2022 00:00:00 +0530 Thu, 12 Jan 2023 14:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432772 Receipts from disaster recovery uplinking and satellite-based telecommunication services were not taxable as royalty because the customers had no possession, control, or right to use the provider's equipment or process; the arrangement was a service contract, and retrospective domestic amendments did not enlarge the treaty definition. Receipts from disaster recovery playout services were not taxable as fees for technical services because the activity did not make available technical knowledge, skill, or know-how, nor was it ancillary or subsidiary in the required sense. On that reasoning, the disputed receipts were treated as non-taxable under the India-Singapore DTAA. Case-Laws Income Tax Mon, 19 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432772