https://www.taxtmi.com/caselaws?id=464189 Borrowed services fees were held not to constitute fee for technical services under the India-Singapore DTAA because the same receipts had already been consistently treated as business profits in the assessee's own earlier years. The record also showed that the issue had been resolved through the Mutual Agreement Procedure and related Department appeals had been withdrawn. In the absence of any distinguishing facts, the receipts remained taxable only as business profits under Article 7 and not in India without a permanent establishment. en-us Fri, 21 Jun 2024 00:00:00 +0530 Thu, 09 Oct 2025 09:52:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464189 Borrowed services fees were held not to constitute fee for technical services under the India-Singapore DTAA because the same receipts had already been consistently treated as business profits in the assessee's own earlier years. The record also showed that the issue had been resolved through the Mutual Agreement Procedure and related Department appeals had been withdrawn. In the absence of any distinguishing facts, the receipts remained taxable only as business profits under Article 7 and not in India without a permanent establishment. Case-Laws Income Tax Fri, 21 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464189