https://www.taxtmi.com/caselaws?id=441453 Fabrication charges for refurbishing bushings were analysed under section 9(1)(vii) and Article 12 of the India-Singapore Tax Treaty to determine whether they constituted fees for technical services. The Tribunal's reasoning, as discussed in the text, was that the work was performed in Singapore, did not make available technical knowledge, skill, experience, or know-how, and could not be recharacterised by reference to payments made to another group entity. Treaty taxation had to be tested on the actual recipient and service arrangement, and ancillary-and-subsidiary character could not be expanded beyond the treaty language. en-us Mon, 22 May 2023 00:00:00 +0530 Tue, 08 Aug 2023 11:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441453 Fabrication charges for refurbishing bushings were analysed under section 9(1)(vii) and Article 12 of the India-Singapore Tax Treaty to determine whether they constituted fees for technical services. The Tribunal's reasoning, as discussed in the text, was that the work was performed in Singapore, did not make available technical knowledge, skill, experience, or know-how, and could not be recharacterised by reference to payments made to another group entity. Treaty taxation had to be tested on the actual recipient and service arrangement, and ancillary-and-subsidiary character could not be expanded beyond the treaty language. Case-Laws Income Tax Mon, 22 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441453