https://www.taxtmi.com/caselaws?id=465928 Intra-group support services were held not taxable as fees for technical services under the India-Singapore DTAA because the support arrangement was separate from the licensing agreement and the services were routine operational, administrative, academic, finance, human resources, and marketing assistance. A mere incidental benefit to the brand did not make the receipts ancillary and subsidiary to the licence for Article 12(4)(a). The record also did not show that technical knowledge, skill, know-how, or experience had been made available to the Indian entity so as to enable independent future performance under Article 12(4)(b). The addition for service fees was deleted. en-us Tue, 21 Nov 2023 00:00:00 +0530 Thu, 15 Jan 2026 18:59:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465928 Intra-group support services were held not taxable as fees for technical services under the India-Singapore DTAA because the support arrangement was separate from the licensing agreement and the services were routine operational, administrative, academic, finance, human resources, and marketing assistance. A mere incidental benefit to the brand did not make the receipts ancillary and subsidiary to the licence for Article 12(4)(a). The record also did not show that technical knowledge, skill, know-how, or experience had been made available to the Indian entity so as to enable independent future performance under Article 12(4)(b). The addition for service fees was deleted. Case-Laws Income Tax Tue, 21 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465928