https://www.taxtmi.com/caselaws?id=444816 The court allowed the condonation of a 45-day delay in re-filing the appeal, as there was no objection from the respondent. The appeal challenged the Income Tax Appellate Tribunal's decision on whether services provided by the respondent to its Indian affiliate constituted 'Fees for Technical Services' under the Indo-Singapore DTAA for the Assessment Year 2019-20. The Tribunal ruled in favor of the respondent, determining that the services did not meet the 'make available' criterion of the DTAA, as they did not enable the recipient to apply the technology independently. The appeal was dismissed, with no substantial question of law arising. en-us Tue, 03 Oct 2023 00:00:00 +0530 Mon, 04 Dec 2023 17:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444816 The court allowed the condonation of a 45-day delay in re-filing the appeal, as there was no objection from the respondent. The appeal challenged the Income Tax Appellate Tribunal's decision on whether services provided by the respondent to its Indian affiliate constituted 'Fees for Technical Services' under the Indo-Singapore DTAA for the Assessment Year 2019-20. The Tribunal ruled in favor of the respondent, determining that the services did not meet the 'make available' criterion of the DTAA, as they did not enable the recipient to apply the technology independently. The appeal was dismissed, with no substantial question of law arising. Case-Laws Income Tax Tue, 03 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444816