https://www.taxtmi.com/highlights?id=97292 Taxation of fees for technical services under Article 12 of the India-Singapore DTAA was addressed: the Tribunal applied the limited scope of Article 9 as a neutralisation rule for intra-group profit adjustments and rejected recharacterisation of the transaction. The assessee, a Singapore entity, was treated as a distinct legal person and its refurbishing services were held not taxable in India because Article 12(3) did not apply and Article 12(4)(a) was inapplicable since the services were not rendered in connection with payments described in paragraph 3. The Tribunal followed coordinate-bench precedent and deleted the addition for fabrication charges; appeal allowed. en-us Sat, 28 Feb 2026 13:59:36 +0530 Sat, 28 Feb 2026 13:59:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97292 Taxation of fees for technical services under Article 12 of the India-Singapore DTAA was addressed: the Tribunal applied the limited scope of Article 9 as a neutralisation rule for intra-group profit adjustments and rejected recharacterisation of the transaction. The assessee, a Singapore entity, was treated as a distinct legal person and its refurbishing services were held not taxable in India because Article 12(3) did not apply and Article 12(4)(a) was inapplicable since the services were not rendered in connection with payments described in paragraph 3. The Tribunal followed coordinate-bench precedent and deleted the addition for fabrication charges; appeal allowed. Highlights Income Tax Sat, 28 Feb 2026 13:59:36 +0530 https://www.taxtmi.com/highlights?id=97292