https://www.taxtmi.com/caselaws?id=776268 Free-of-cost equipment supplied by associated enterprises for use in software development, and required to be returned, was not taxable under section 28(iv) where the APA already accounted for the relevant assets and depreciation, so no further addition survived. Payments for employee training workshops on performance and career management were not fees for technical services under the India-Singapore DTAA because the training did not make available technical knowledge, experience, skill, know-how, or processes, so disallowance under section 40(a)(i) was not sustainable. The treaty definition controlled the characterisation of the payment, and relief was upheld. en-us Mon, 28 Jul 2025 00:00:00 +0530 Thu, 07 Aug 2025 08:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776268 Free-of-cost equipment supplied by associated enterprises for use in software development, and required to be returned, was not taxable under section 28(iv) where the APA already accounted for the relevant assets and depreciation, so no further addition survived. Payments for employee training workshops on performance and career management were not fees for technical services under the India-Singapore DTAA because the training did not make available technical knowledge, experience, skill, know-how, or processes, so disallowance under section 40(a)(i) was not sustainable. The treaty definition controlled the characterisation of the payment, and relief was upheld. Case-Laws Income Tax Mon, 28 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776268