https://www.taxtmi.com/caselaws?id=779126 Receipts from borrowed services were held not to fall within fees for technical services under Article 12 of the India-Singapore DTAA because the factual matrix matched earlier decisions in the assessee's own case and connected matters, and no distinguishing material showed that the treaty test for such taxation was satisfied. The Commissioner (Appeals) followed the prior year decision and granted relief, and that approach was upheld in favour of the assessee. en-us Mon, 20 Jan 2025 00:00:00 +0530 Sat, 27 Sep 2025 12:14:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779126 Receipts from borrowed services were held not to fall within fees for technical services under Article 12 of the India-Singapore DTAA because the factual matrix matched earlier decisions in the assessee's own case and connected matters, and no distinguishing material showed that the treaty test for such taxation was satisfied. The Commissioner (Appeals) followed the prior year decision and granted relief, and that approach was upheld in favour of the assessee. Case-Laws Income Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779126