https://www.taxtmi.com/caselaws?id=790323 Voice termination, bandwidth and O&M service receipts were not taxable in India as royalty or fees for technical services where the treaty 'make available' threshold was not met. The India-Singapore and India-USA treaty provisions were treated as materially comparable, and the receipts were consequently characterised as business profits not taxable without a permanent establishment. The reopening and assessment-limitation challenge became infructuous following the Finance Act, 2026 amendment to section 153B, without adjudication on its merits. The taxpayer obtained relief on the substantive taxability issue but not on the reopening and limitation ground. en-us Fri, 17 Apr 2026 00:00:00 +0530 Thu, 23 Apr 2026 09:45:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790323 Voice termination, bandwidth and O&M service receipts were not taxable in India as royalty or fees for technical services where the treaty 'make available' threshold was not met. The India-Singapore and India-USA treaty provisions were treated as materially comparable, and the receipts were consequently characterised as business profits not taxable without a permanent establishment. The reopening and assessment-limitation challenge became infructuous following the Finance Act, 2026 amendment to section 153B, without adjudication on its merits. The taxpayer obtained relief on the substantive taxability issue but not on the reopening and limitation ground. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790323