https://www.taxtmi.com/caselaws?id=777418 Management fee paid to the Singapore entity was held not taxable as fee for technical services under Article 12(4)(b) of the India-Singapore DTAA because the services did not make available technical knowledge, skill, know-how or processes to the recipient; the addition was deleted. Interest under section 234A was also held not leviable because the return was filed within the extended due date. Interest under section 234B was sustained as mandatory on the facts found. The question of refund adjustment in computing demand was remitted to the Assessing Officer for factual verification and recomputation. en-us Tue, 26 Aug 2025 00:00:00 +0530 Fri, 29 Aug 2025 08:56:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777418 Management fee paid to the Singapore entity was held not taxable as fee for technical services under Article 12(4)(b) of the India-Singapore DTAA because the services did not make available technical knowledge, skill, know-how or processes to the recipient; the addition was deleted. Interest under section 234A was also held not leviable because the return was filed within the extended due date. Interest under section 234B was sustained as mandatory on the facts found. The question of refund adjustment in computing demand was remitted to the Assessing Officer for factual verification and recomputation. Case-Laws Income Tax Tue, 26 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777418