https://www.taxtmi.com/caselaws?id=447867 Receipts from management support services were examined under Article 12(4)(b) of the India-Singapore DTAA and section 9(1)(vii) to determine whether they constituted fee for technical services. The services were intermediary and support functions, including administration, marketing, sales, bids, engineering, quality, procurement, project management and programme management. The decisive issue was whether the provider made available technical knowledge, know-how, skill or processes so the recipient could apply them independently in future. As the authorities did not establish this make-available condition with cogent evidence, the receipts were not characterised as fee for technical services and the related addition was deleted. en-us Mon, 30 Oct 2023 00:00:00 +0530 Fri, 05 Jan 2024 15:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447867 Receipts from management support services were examined under Article 12(4)(b) of the India-Singapore DTAA and section 9(1)(vii) to determine whether they constituted fee for technical services. The services were intermediary and support functions, including administration, marketing, sales, bids, engineering, quality, procurement, project management and programme management. The decisive issue was whether the provider made available technical knowledge, know-how, skill or processes so the recipient could apply them independently in future. As the authorities did not establish this make-available condition with cogent evidence, the receipts were not characterised as fee for technical services and the related addition was deleted. Case-Laws Income Tax Mon, 30 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447867