https://www.taxtmi.com/caselaws?id=435801 Management support services comprising operational, accounting, legal, procurement, IT and training support were held not to constitute fees for technical services under the India-Singapore DTAA or section 9(1)(vii) because they did not make available technical knowledge, skill, experience, know-how or processes for independent future use. The arrangement was also found separate from the brand licence, so the receipt was not ancillary and subsidiary to royalty under Article 12(4)(a). The earlier year's precedent was followed, and the tax addition was deleted. en-us Wed, 11 Jan 2023 00:00:00 +0530 Mon, 27 Mar 2023 18:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435801 Management support services comprising operational, accounting, legal, procurement, IT and training support were held not to constitute fees for technical services under the India-Singapore DTAA or section 9(1)(vii) because they did not make available technical knowledge, skill, experience, know-how or processes for independent future use. The arrangement was also found separate from the brand licence, so the receipt was not ancillary and subsidiary to royalty under Article 12(4)(a). The earlier year's precedent was followed, and the tax addition was deleted. Case-Laws Income Tax Wed, 11 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435801