https://www.taxtmi.com/caselaws?id=785120 Receipts under a principal-to-principal distribution arrangement are not fees for technical services where the distributor does not render technical, managerial or consultancy services and no make-available obligation is shown. The IndiaSingapore DTAA governs a Singapore resident assessee with a valid tax residency certificate, and the IndiaSwitzerland DTAA cannot be invoked for that taxpayer. Because the receipts are not royalty or FTS under the Act or treaty, section 10(50) exclusion for income subject to Equalization Levy remains available, subject to verification of levy payment. TDS credit is to be verified and granted in accordance with law. en-us Tue, 30 Dec 2025 00:00:00 +0530 Sat, 17 Jan 2026 08:45:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785120 Receipts under a principal-to-principal distribution arrangement are not fees for technical services where the distributor does not render technical, managerial or consultancy services and no make-available obligation is shown. The IndiaSingapore DTAA governs a Singapore resident assessee with a valid tax residency certificate, and the IndiaSwitzerland DTAA cannot be invoked for that taxpayer. Because the receipts are not royalty or FTS under the Act or treaty, section 10(50) exclusion for income subject to Equalization Levy remains available, subject to verification of levy payment. TDS credit is to be verified and granted in accordance with law. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785120