https://www.taxtmi.com/caselaws?id=308582 Under the India-Singapore DTAA, consultancy and project-related design services are taxable as fees for technical services only if they make available technical knowledge, experience, skill, know-how or processes so the recipient can apply them independently in future, or if they involve transfer of a technical plan or design. On the stated facts, the services were project-specific and no material showed that any such technical knowledge or design was made available to the Indian payer. The non-resident also had no permanent establishment in India, supporting the position that no tax was required to be withheld under section 195 and that consequential demand under sections 201(1) and 201(1A) would not arise. en-us Mon, 05 Sep 2022 00:00:00 +0530 Wed, 05 Jul 2023 20:51:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308582 Under the India-Singapore DTAA, consultancy and project-related design services are taxable as fees for technical services only if they make available technical knowledge, experience, skill, know-how or processes so the recipient can apply them independently in future, or if they involve transfer of a technical plan or design. On the stated facts, the services were project-specific and no material showed that any such technical knowledge or design was made available to the Indian payer. The non-resident also had no permanent establishment in India, supporting the position that no tax was required to be withheld under section 195 and that consequential demand under sections 201(1) and 201(1A) would not arise. Case-Laws Income Tax Mon, 05 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308582