https://www.taxtmi.com/caselaws?id=770819 Fabrication charges received from an Indian associated enterprise were examined for taxability as fees for technical services under section 9(1)(vii) and Article 12 of the India-Singapore DTAA. The earlier coordinate-bench view in the assessee's own case held that the receipts did not satisfy the treaty definition of fees for technical services, and no change in facts or law was shown for the year under review. Applying the narrower treaty test and following the recurring prior decision, the receipts were treated as not taxable as FTS, and the addition was deleted. en-us Wed, 14 May 2025 00:00:00 +0530 Fri, 16 May 2025 10:32:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770819 Fabrication charges received from an Indian associated enterprise were examined for taxability as fees for technical services under section 9(1)(vii) and Article 12 of the India-Singapore DTAA. The earlier coordinate-bench view in the assessee's own case held that the receipts did not satisfy the treaty definition of fees for technical services, and no change in facts or law was shown for the year under review. Applying the narrower treaty test and following the recurring prior decision, the receipts were treated as not taxable as FTS, and the addition was deleted. Case-Laws Income Tax Wed, 14 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770819