https://www.taxtmi.com/caselaws?id=785614 Receipts from ancillary support services linked to software licence distribution were not treated as Fees for Technical Services under the India-Singapore DTAA or the Income-tax Act. Although the services were separately invoiced, the agreement and surrounding terms showed that they formed part of the support and maintenance framework attached to the software licence arrangement. On the facts, the separate billing did not establish independent technical services, and the record did not support a finding that technical knowledge or skills were made available. The addition was deleted, and the receipts were held taxable as part of the software licence activity rather than as stand-alone FTS. 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 Receipts from ancillary support services linked to software licence distribution were not treated as Fees for Technical Services under the India-Singapore DTAA or the Income-tax Act. Although the services were separately invoiced, the agreement and surrounding terms showed that they formed part of the support and maintenance framework attached to the software licence arrangement. On the facts, the separate billing did not establish independent technical services, and the record did not support a finding that technical knowledge or skills were made available. The addition was deleted, and the receipts were held taxable as part of the software licence activity rather than as stand-alone FTS. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785614