https://www.taxtmi.com/caselaws?id=307479 Fabrication charges for refurbishing bushings, carried out in Singapore without an Indian PE, were discussed under section 9(1)(vii) of the Income-tax Act and Article 12 of the India-Singapore DTAA. The article states that Article 12(4)(a) applies only where the assessee itself receives a payment described in Article 12(3), and that Article 9 cannot be used to recharacterise payments between distinct legal entities. Respecting the separate identity of the group entities, the receipts were held not to fall within fees for technical services, and the addition was deleted in favour of the assessee. en-us Mon, 26 Dec 2022 00:00:00 +0530 Sun, 16 Apr 2023 17:07:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307479 Fabrication charges for refurbishing bushings, carried out in Singapore without an Indian PE, were discussed under section 9(1)(vii) of the Income-tax Act and Article 12 of the India-Singapore DTAA. The article states that Article 12(4)(a) applies only where the assessee itself receives a payment described in Article 12(3), and that Article 9 cannot be used to recharacterise payments between distinct legal entities. Respecting the separate identity of the group entities, the receipts were held not to fall within fees for technical services, and the addition was deleted in favour of the assessee. Case-Laws Income Tax Mon, 26 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307479