https://www.taxtmi.com/caselaws?id=758854 Management service fees received for multiple services to an associated enterprise in India were examined under Article 12 of the India-Singapore DTAA. Information technology services were treated as not taxable because the make-available condition was not satisfied. The remaining planning and analysis, human resources, and finance services were not finally determined on taxability because the record was said to be incomplete and the nature of services had not been fully examined. The matter was restored for fresh consideration on the existing material, with permission to examine further evidence, and a speaking order was directed in accordance with law. en-us Fri, 31 May 2024 00:00:00 +0530 Fri, 20 Sep 2024 08:31:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758854 Management service fees received for multiple services to an associated enterprise in India were examined under Article 12 of the India-Singapore DTAA. Information technology services were treated as not taxable because the make-available condition was not satisfied. The remaining planning and analysis, human resources, and finance services were not finally determined on taxability because the record was said to be incomplete and the nature of services had not been fully examined. The matter was restored for fresh consideration on the existing material, with permission to examine further evidence, and a speaking order was directed in accordance with law. Case-Laws Income Tax Fri, 31 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758854