https://www.taxtmi.com/caselaws?id=444076 Under the India-Singapore DTAA, management support, finance and treasury, legal support, IT support, HR and administrative support, as well as marketing and sales and operations and standardization services, did not satisfy the "make available" condition in Article 12(4)(b) because they conveyed advice, guidance, reports, manuals, and standards, but not the underlying technical knowledge, skill, know-how, or process enabling independent future use. They were therefore not taxable as fees for technical services. The question of interest under sections 234A and 234B was remanded to the Assessing Officer for fresh adjudication in accordance with law. en-us Mon, 25 Sep 2023 00:00:00 +0530 Wed, 31 Jan 2024 14:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444076 Under the India-Singapore DTAA, management support, finance and treasury, legal support, IT support, HR and administrative support, as well as marketing and sales and operations and standardization services, did not satisfy the "make available" condition in Article 12(4)(b) because they conveyed advice, guidance, reports, manuals, and standards, but not the underlying technical knowledge, skill, know-how, or process enabling independent future use. They were therefore not taxable as fees for technical services. The question of interest under sections 234A and 234B was remanded to the Assessing Officer for fresh adjudication in accordance with law. Case-Laws Income Tax Mon, 25 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444076