https://www.taxtmi.com/caselaws?id=760047 Technical inspection and integrity assessment receipts were treated as business profits under the India-Singapore DTAA because the services, though technical, did not satisfy the "make available" requirement in Article 12(4)(b). As a result, they could not be taxed as fees for technical services under the treaty. The receipts therefore fell within Article 7, and in the absence of a permanent establishment in India, they were not taxable in India. The first appellate factual findings on the nature of the services were not controverted. en-us Thu, 03 Oct 2024 00:00:00 +0530 Tue, 15 Oct 2024 08:39:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760047 Technical inspection and integrity assessment receipts were treated as business profits under the India-Singapore DTAA because the services, though technical, did not satisfy the "make available" requirement in Article 12(4)(b). As a result, they could not be taxed as fees for technical services under the treaty. The receipts therefore fell within Article 7, and in the absence of a permanent establishment in India, they were not taxable in India. The first appellate factual findings on the nature of the services were not controverted. Case-Laws Income Tax Thu, 03 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760047