Income tax treatment of ancillary support services for software licenses under IndiaSingapore DTAA found not to be FTS, relief granted https://www.taxtmi.com/highlights?id=96407 Whether consideration for ancillary support services connected to software license distribution constitutes Fee for Technical Services under the IndiaSingapore DTAA. The tribunal found the services were ancillary and subsidiary to software sales, including maintenance and technical support obligations under the parties' licence and partner agreements, and thus not characterisable as FTS or as "make available" independent services; consequence: the assessing officer/TPA/DRP findings treating the receipts as FTS were not justified and were disallowed to that extent. en-us Wed, 28 Jan 2026 07:26:20 +0530 Wed, 28 Jan 2026 07:26:22 +0530 TaxTMI RSS Generator Income tax treatment of ancillary support services for software licenses under IndiaSingapore DTAA found not to be FTS, relief granted https://www.taxtmi.com/highlights?id=96407 Whether consideration for ancillary support services connected to software license distribution constitutes Fee for Technical Services under the IndiaSingapore DTAA. The tribunal found the services were ancillary and subsidiary to software sales, including maintenance and technical support obligations under the parties' licence and partner agreements, and thus not characterisable as FTS or as "make available" independent services; consequence: the assessing officer/TPA/DRP findings treating the receipts as FTS were not justified and were disallowed to that extent. Highlights Income Tax Wed, 28 Jan 2026 07:26:20 +0530 https://www.taxtmi.com/highlights?id=96407