https://www.taxtmi.com/caselaws?id=462099 Receipts from business support and referral services were held not to constitute fees for technical services under the India-Singapore DTAA because the services did not satisfy the treaty's "make available" : the recipient was not enabled to independently apply the technical knowledge, skill or know-how after the services ended, and a mere incidental benefit was insufficient. As the treaty position prevailed, section 90(2) prevented the domestic Act from altering that result, and the addition treating the receipts as taxable fees for technical services was directed to be deleted. en-us Fri, 02 Dec 2022 00:00:00 +0530 Thu, 22 May 2025 20:04:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462099 Receipts from business support and referral services were held not to constitute fees for technical services under the India-Singapore DTAA because the services did not satisfy the treaty's "make available" : the recipient was not enabled to independently apply the technical knowledge, skill or know-how after the services ended, and a mere incidental benefit was insufficient. As the treaty position prevailed, section 90(2) prevented the domestic Act from altering that result, and the addition treating the receipts as taxable fees for technical services was directed to be deleted. Case-Laws Income Tax Fri, 02 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462099