https://www.taxtmi.com/highlights?id=72439 Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy the “make available” clause as per article 12(4)(b) of Indo Singapore DTAA and, therefore, the amounts are attributable for these services cannot be held to be fees for technical services. - AT en-us Mon, 09 Oct 2023 08:41:37 +0530 Mon, 09 Oct 2023 08:41:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=72439 Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy the “make available” clause as per article 12(4)(b) of Indo Singapore DTAA and, therefore, the amounts are attributable for these services cannot be held to be fees for technical services. - AT Highlights Income Tax Mon, 09 Oct 2023 08:41:37 +0530 https://www.taxtmi.com/highlights?id=72439