https://www.taxtmi.com/caselaws?id=439861 A valid Singapore tax residency certificate, supported by incorporation and filing records, established treaty eligibility, and treaty benefits could not be denied absent fraud or sham. The online platform arrangement did not create a business connection or dependent agent permanent establishment in India because the intermediary acted independently in the ordinary course of business, so no business income accrued or arose in India. The subscription receipts also were not fees for technical services, as the facility involved only standard online listing and display services without technical, managerial, consultancy character or the level of human intervention required for such classification. en-us Fri, 16 Jun 2023 00:00:00 +0530 Fri, 16 Jan 2026 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439861 A valid Singapore tax residency certificate, supported by incorporation and filing records, established treaty eligibility, and treaty benefits could not be denied absent fraud or sham. The online platform arrangement did not create a business connection or dependent agent permanent establishment in India because the intermediary acted independently in the ordinary course of business, so no business income accrued or arose in India. The subscription receipts also were not fees for technical services, as the facility involved only standard online listing and display services without technical, managerial, consultancy character or the level of human intervention required for such classification. Case-Laws Income Tax Fri, 16 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439861