https://www.taxtmi.com/caselaws?id=441520 Project-specific architectural design services rendered to Indian clients were held not to be fees for technical services under Article 12(4)(c) of the India-Singapore DTAA because the work did not transfer technical knowledge, know-how, or any reusable capability enabling the clients to apply the technology independently. The receipts were also held not to be royalty under Article 12(3) because the contracts covered development and transfer of designs for specific projects, not a bare right to use existing designs or copyright. On that reasoning, the design-service receipts were not taxable as FTS or royalty. en-us Mon, 10 Jul 2023 00:00:00 +0530 Wed, 25 Mar 2026 09:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441520 Project-specific architectural design services rendered to Indian clients were held not to be fees for technical services under Article 12(4)(c) of the India-Singapore DTAA because the work did not transfer technical knowledge, know-how, or any reusable capability enabling the clients to apply the technology independently. The receipts were also held not to be royalty under Article 12(3) because the contracts covered development and transfer of designs for specific projects, not a bare right to use existing designs or copyright. On that reasoning, the design-service receipts were not taxable as FTS or royalty. Case-Laws Income Tax Mon, 10 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441520