https://www.taxtmi.com/caselaws?id=446406 Management support charges under the India-Singapore treaty were held not to constitute fees for technical services because the services, though managerial and consultancy in nature, did not satisfy the treaty's make available test. The Tribunal also found that the support arrangement was independent of the brand licence contracts, so the receipts could not be characterised as ancillary and subsidiary to the royalty stream. The amounts were therefore treated as business income, and the transfer of the addition was deleted in favour of the assessee. en-us Wed, 05 Apr 2023 00:00:00 +0530 Sat, 02 Dec 2023 10:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446406 Management support charges under the India-Singapore treaty were held not to constitute fees for technical services because the services, though managerial and consultancy in nature, did not satisfy the treaty's make available test. The Tribunal also found that the support arrangement was independent of the brand licence contracts, so the receipts could not be characterised as ancillary and subsidiary to the royalty stream. The amounts were therefore treated as business income, and the transfer of the addition was deleted in favour of the assessee. Case-Laws Income Tax Wed, 05 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446406