https://www.taxtmi.com/caselaws?id=762208 Receipts from repair and maintenance of aircraft equipment performed outside India were not fee for technical services because no technical knowledge, skill, know-how, design or training was made available to the recipient, and the treaty's make available condition was not met. The tribunal therefore held the receipts not taxable under section 9(1)(vii) or the India-Singapore treaty. Interest under section 234A was left for verification by the Assessing Officer based on the due date issue, while section 234B was treated as consequential. Penalty proceedings under section 270A did not survive once the underlying addition was deleted. en-us Thu, 14 Nov 2024 00:00:00 +0530 Tue, 26 Nov 2024 11:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762208 Receipts from repair and maintenance of aircraft equipment performed outside India were not fee for technical services because no technical knowledge, skill, know-how, design or training was made available to the recipient, and the treaty's make available condition was not met. The tribunal therefore held the receipts not taxable under section 9(1)(vii) or the India-Singapore treaty. Interest under section 234A was left for verification by the Assessing Officer based on the due date issue, while section 234B was treated as consequential. Penalty proceedings under section 270A did not survive once the underlying addition was deleted. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762208