https://www.taxtmi.com/highlights?id=96758 TDS on cross border service charges was examined as fees for technical services under the India-Singapore DTAA, which, if more beneficial, prevails and renders the impugned TDS liability unsustainable. The High Court held that the Assessing Officer (TDS) may independently initiate proceedings treating a payer as an assessee in default, regardless of a concurrent scrutiny assessment under Section 143(3); such proceedings are separate and can impose interest and penalty. However, the AO(TDS) wrongly disregarded DTAA applicability and relied on invoice descriptions; consequently the order declaring the petitioner an assessee in default was quashed and set aside. en-us Tue, 10 Feb 2026 07:46:24 +0530 Tue, 10 Feb 2026 07:46:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96758 TDS on cross border service charges was examined as fees for technical services under the India-Singapore DTAA, which, if more beneficial, prevails and renders the impugned TDS liability unsustainable. The High Court held that the Assessing Officer (TDS) may independently initiate proceedings treating a payer as an assessee in default, regardless of a concurrent scrutiny assessment under Section 143(3); such proceedings are separate and can impose interest and penalty. However, the AO(TDS) wrongly disregarded DTAA applicability and relied on invoice descriptions; consequently the order declaring the petitioner an assessee in default was quashed and set aside. Highlights Income Tax Tue, 10 Feb 2026 07:46:24 +0530 https://www.taxtmi.com/highlights?id=96758