https://www.taxtmi.com/caselaws?id=442278 Receipts from interior design consultancy under a project work order were treated as fees for technical services under Article 12 of the India-Singapore DTAA because the contract covered preparation of designs, plans and drawings, together with transfer of rights and a licence to use, copy, modify and create derivative works from the embedded intellectual property. The nature of the deliverables went beyond mere advisory assistance and satisfied Article 12(4)(b) and Article 12(4)(c), so the treaty classification was upheld. A separate objection regarding alleged duplication of returned income was not decided on merits and was remanded to the Assessing Officer for fresh consideration. en-us Fri, 25 Aug 2023 00:00:00 +0530 Mon, 28 Aug 2023 08:18:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442278 Receipts from interior design consultancy under a project work order were treated as fees for technical services under Article 12 of the India-Singapore DTAA because the contract covered preparation of designs, plans and drawings, together with transfer of rights and a licence to use, copy, modify and create derivative works from the embedded intellectual property. The nature of the deliverables went beyond mere advisory assistance and satisfied Article 12(4)(b) and Article 12(4)(c), so the treaty classification was upheld. A separate objection regarding alleged duplication of returned income was not decided on merits and was remanded to the Assessing Officer for fresh consideration. Case-Laws Income Tax Fri, 25 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442278