https://www.taxtmi.com/caselaws?id=461219 Receipts from ongoing IT and administrative support services to an Indian affiliate were not fees for technical services under Article 12(4)(b) of the India-Singapore DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes for independent use by the recipient. The recurring group-support arrangement showed continued dependence on the provider, and mere incidental or enduring benefit was insufficient without transfer of technology or independent usability. On that basis, the receipts were not taxable as fees for technical services and the additions were deleted. en-us Fri, 30 Dec 2022 00:00:00 +0530 Fri, 21 Mar 2025 19:21:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461219 Receipts from ongoing IT and administrative support services to an Indian affiliate were not fees for technical services under Article 12(4)(b) of the India-Singapore DTAA because the services did not make available technical knowledge, experience, skill, know-how or processes for independent use by the recipient. The recurring group-support arrangement showed continued dependence on the provider, and mere incidental or enduring benefit was insufficient without transfer of technology or independent usability. On that basis, the receipts were not taxable as fees for technical services and the additions were deleted. Case-Laws Income Tax Fri, 30 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461219