https://www.taxtmi.com/caselaws?id=785614 Treatment of cross-border ancillary support provided with software license distribution under the IndiaSingapore DTAA is examined; the services constituted technical support and maintenance ancillary to software sales rather than independent fees for technical services. The reasoning relied on contractual definitions (including maintenance as provision of new releases/versions and active support), the linkage between support and original software sales under the reseller/partner agreement and EULAs, and the absence of evidence that services amounted to 'make available'. Consequent operative effect: characterisation as ancillary to product sale, not FTS, renders the assessing/TPO findings unjustified. en-us Tue, 16 Dec 2025 00:00:00 +0530 Tue, 27 Jan 2026 18:34:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785614 Treatment of cross-border ancillary support provided with software license distribution under the IndiaSingapore DTAA is examined; the services constituted technical support and maintenance ancillary to software sales rather than independent fees for technical services. The reasoning relied on contractual definitions (including maintenance as provision of new releases/versions and active support), the linkage between support and original software sales under the reseller/partner agreement and EULAs, and the absence of evidence that services amounted to 'make available'. Consequent operative effect: characterisation as ancillary to product sale, not FTS, renders the assessing/TPO findings unjustified. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785614