https://www.taxtmi.com/caselaws?id=770439 Receipts from maintenance and training services provided by a Singapore resident to Indian customers were held not taxable as fees for technical services under Article 12 of the India-Singapore DTAA or section 9(1). The services consisted of remote support for software bugs and usage issues, together with basic training for proper software use, but they did not make available technical knowledge, skill, experience or know-how to the customers. The assistance was treated as ancillary support linked to software licensing, and the fact that it was rendered by technical personnel or through remote means did not alter the treaty position. The addition made by the Assessing Officer was deleted. en-us Thu, 08 May 2025 00:00:00 +0530 Sat, 10 May 2025 08:36:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770439 Receipts from maintenance and training services provided by a Singapore resident to Indian customers were held not taxable as fees for technical services under Article 12 of the India-Singapore DTAA or section 9(1). The services consisted of remote support for software bugs and usage issues, together with basic training for proper software use, but they did not make available technical knowledge, skill, experience or know-how to the customers. The assistance was treated as ancillary support linked to software licensing, and the fact that it was rendered by technical personnel or through remote means did not alter the treaty position. The addition made by the Assessing Officer was deleted. Case-Laws Income Tax Thu, 08 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770439