https://www.taxtmi.com/caselaws?id=789053 Payments to Singapore-based consultants for project-specific architectural, structural design and consultancy services were not fees for technical services under Article 12(4) of the India-Singapore DTAA because the services were confined to one real estate project and no technical knowledge, skill, know-how or process was made available for independent future use. The tribunal followed its earlier year's identical decision and held that the treaty conditions were not satisfied, so the related disallowance under section 40(a)(i) could not survive. en-us Mon, 30 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789053 Payments to Singapore-based consultants for project-specific architectural, structural design and consultancy services were not fees for technical services under Article 12(4) of the India-Singapore DTAA because the services were confined to one real estate project and no technical knowledge, skill, know-how or process was made available for independent future use. The tribunal followed its earlier year's identical decision and held that the treaty conditions were not satisfied, so the related disallowance under section 40(a)(i) could not survive. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789053