https://www.taxtmi.com/caselaws?id=789053 Payments to Singapore-based entities for architectural, consultancy and structural design services for a specific real estate project were not fees for technical services under Article 12(4) of the India-Singapore DTAA. The treaty applied only where technical, managerial or consultancy services made available technical knowledge, experience, skill, know-how or processes enabling independent use by the recipient, or involved development and transfer of a technical plan or design. Because the services were confined to project-specific drawings and consultancy and no transferable technical know-how was shown, no tax deduction obligation arose under section 195 of the Income-tax Act, 1961, and disallowance under section 40(a)(i) was not warranted. en-us Mon, 30 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789053 Payments to Singapore-based entities for architectural, consultancy and structural design services for a specific real estate project were not fees for technical services under Article 12(4) of the India-Singapore DTAA. The treaty applied only where technical, managerial or consultancy services made available technical knowledge, experience, skill, know-how or processes enabling independent use by the recipient, or involved development and transfer of a technical plan or design. Because the services were confined to project-specific drawings and consultancy and no transferable technical know-how was shown, no tax deduction obligation arose under section 195 of the Income-tax Act, 1961, and disallowance under section 40(a)(i) was not warranted. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789053