https://www.taxtmi.com/caselaws?id=753715 Management service fees paid to a Singapore group entity were not taxable as fees for technical services or as fees for included services under Article 12(4)(b) of the India-Singapore DTAA because the revenue authorities did not show that technical knowledge, skill, know-how or processes were made available to the Indian recipient. Receipts from sale of software licences to an Indian bank were also not taxable as fees for technical services because the arrangement was a licence to install and use software on specified terms, not a rendering of technical services. The disputed additions therefore failed on both issues. en-us Wed, 17 Jan 2024 00:00:00 +0530 Fri, 23 May 2025 16:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753715 Management service fees paid to a Singapore group entity were not taxable as fees for technical services or as fees for included services under Article 12(4)(b) of the India-Singapore DTAA because the revenue authorities did not show that technical knowledge, skill, know-how or processes were made available to the Indian recipient. Receipts from sale of software licences to an Indian bank were also not taxable as fees for technical services because the arrangement was a licence to install and use software on specified terms, not a rendering of technical services. The disputed additions therefore failed on both issues. Case-Laws Income Tax Wed, 17 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753715