https://www.taxtmi.com/caselaws?id=771216 Management support service receipts were treated as fees for technical services under Article 12(4) of the India-Singapore DTAA only if the make available test was satisfied, meaning technical knowledge, skill or know-how had to be transferred so the recipient could apply it independently after the service ended. Mere receipt of benefit or incidental advantage was insufficient. Applying the coordinate bench view in the assessee's own earlier years and finding no change in facts or law, the receipts were held not taxable as fees for technical services and the addition was deleted. Penalty initiation under section 270A was noted as merely proposed in the assessment order and was treated as premature at that stage. en-us Thu, 15 May 2025 00:00:00 +0530 Thu, 22 May 2025 08:21:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771216 Management support service receipts were treated as fees for technical services under Article 12(4) of the India-Singapore DTAA only if the make available test was satisfied, meaning technical knowledge, skill or know-how had to be transferred so the recipient could apply it independently after the service ended. Mere receipt of benefit or incidental advantage was insufficient. Applying the coordinate bench view in the assessee's own earlier years and finding no change in facts or law, the receipts were held not taxable as fees for technical services and the addition was deleted. Penalty initiation under section 270A was noted as merely proposed in the assessment order and was treated as premature at that stage. Case-Laws Income Tax Thu, 15 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771216