https://www.taxtmi.com/caselaws?id=767481 ITAT Mumbai ruled in favor of the assessee regarding fabrication charges received from India. The AO had treated these charges as fees for technical services under the India-Singapore DTAA and imposed 10% tax. The tribunal held that fabrication charges for bushings cannot be classified as fees for technical services under Article 12(4)(a) of the DTAA, as no royalty was received per Article 12(3). This decision was consistent with ITAT's rulings in the assessee's favor for assessment years 2015-16 to 2020-21 on the same recurring issue. en-us Tue, 18 Feb 2025 00:00:00 +0530 Wed, 19 Mar 2025 06:45:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767481 ITAT Mumbai ruled in favor of the assessee regarding fabrication charges received from India. The AO had treated these charges as fees for technical services under the India-Singapore DTAA and imposed 10% tax. The tribunal held that fabrication charges for bushings cannot be classified as fees for technical services under Article 12(4)(a) of the DTAA, as no royalty was received per Article 12(3). This decision was consistent with ITAT's rulings in the assessee's favor for assessment years 2015-16 to 2020-21 on the same recurring issue. Case-Laws Income Tax Tue, 18 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767481