https://www.taxtmi.com/caselaws?id=437137 Receipts from project-related services were treated as business profits, not royalty or fees for technical services, because the India-Singapore DTAA test was not satisfied and the services did not make available technical knowledge, experience, skill, know-how or processes to the recipient; absent a permanent establishment, the income was not taxable in India. The regional service agreement required fresh examination because its factual matrix and service character had not been fully analysed. Short TDS credit was to be verified and corrected by the Assessing Officer, interest under section 234B was consequential, and initiation of penalty proceedings under section 270A was considered premature. en-us Fri, 31 Mar 2023 00:00:00 +0530 Thu, 27 Apr 2023 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437137 Receipts from project-related services were treated as business profits, not royalty or fees for technical services, because the India-Singapore DTAA test was not satisfied and the services did not make available technical knowledge, experience, skill, know-how or processes to the recipient; absent a permanent establishment, the income was not taxable in India. The regional service agreement required fresh examination because its factual matrix and service character had not been fully analysed. Short TDS credit was to be verified and corrected by the Assessing Officer, interest under section 234B was consequential, and initiation of penalty proceedings under section 270A was considered premature. Case-Laws Income Tax Fri, 31 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437137