https://www.taxtmi.com/highlights?id=96447 ITAT considered whether cross-border corporate service payments attracted TDS under section 195 by examining classification as fees for technical services and existence of a permanent establishment. The tribunal found the services did not make available technical knowledge, experience, skill, know-how or processes, so the payments did not qualify as FTS under the IndiaSingapore DTAA and were at best business profits. It further held there was no fixed-place PE nor dependent agent PE on the record, and mere remote support/coordination was insufficient; consequently the receipts were not taxable in India and no TDS obligation arose, so section 40(a)(i) invocation was unwarranted and the appeal was allowed. en-us Fri, 30 Jan 2026 09:22:24 +0530 Fri, 30 Jan 2026 09:22:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96447 ITAT considered whether cross-border corporate service payments attracted TDS under section 195 by examining classification as fees for technical services and existence of a permanent establishment. The tribunal found the services did not make available technical knowledge, experience, skill, know-how or processes, so the payments did not qualify as FTS under the IndiaSingapore DTAA and were at best business profits. It further held there was no fixed-place PE nor dependent agent PE on the record, and mere remote support/coordination was insufficient; consequently the receipts were not taxable in India and no TDS obligation arose, so section 40(a)(i) invocation was unwarranted and the appeal was allowed. Highlights Income Tax Fri, 30 Jan 2026 09:22:24 +0530 https://www.taxtmi.com/highlights?id=96447