https://www.taxtmi.com/caselaws?id=443600 Receipts from distribution of software products purchased from third-party vendors could not be re-characterised as fees for technical services absent evidence of a separate service element in the invoices or any distinct technical service rendered. The record was materially similar to the earlier year, and there was no cogent basis to treat the receipts differently under the Income-tax Act, 1961. The India-Singapore treaty also required the make available condition, but the facts did not show that technical knowledge, know-how or skill had been enabled for independent future use. The additions were therefore unsustainable and were deleted. en-us Mon, 25 Sep 2023 00:00:00 +0530 Wed, 27 Dec 2023 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443600 Receipts from distribution of software products purchased from third-party vendors could not be re-characterised as fees for technical services absent evidence of a separate service element in the invoices or any distinct technical service rendered. The record was materially similar to the earlier year, and there was no cogent basis to treat the receipts differently under the Income-tax Act, 1961. The India-Singapore treaty also required the make available condition, but the facts did not show that technical knowledge, know-how or skill had been enabled for independent future use. The additions were therefore unsustainable and were deleted. Case-Laws Income Tax Mon, 25 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443600