https://www.taxtmi.com/caselaws?id=438236 Maintenance, support and training receipts for software were examined under section 9(1)(vii) of the Income-tax Act and Article 12(4) of the India-Singapore DTAA. The services consisted of telephone, email and remote-login assistance, corrective maintenance, standard updates and user training, with the customer's in-house team acting as the interface for bug reports and operational issues. On those facts, the arrangement was treated as troubleshooting and support for software already supplied, not as a transfer of technical knowledge, experience, skill, know-how or process that enabled independent use by the customer. The make-available condition was therefore not satisfied, and the receipts were not taxable as fees for technical services. en-us Mon, 08 May 2023 00:00:00 +0530 Mon, 03 Feb 2025 10:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438236 Maintenance, support and training receipts for software were examined under section 9(1)(vii) of the Income-tax Act and Article 12(4) of the India-Singapore DTAA. The services consisted of telephone, email and remote-login assistance, corrective maintenance, standard updates and user training, with the customer's in-house team acting as the interface for bug reports and operational issues. On those facts, the arrangement was treated as troubleshooting and support for software already supplied, not as a transfer of technical knowledge, experience, skill, know-how or process that enabled independent use by the customer. The make-available condition was therefore not satisfied, and the receipts were not taxable as fees for technical services. Case-Laws Income Tax Mon, 08 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438236