https://www.taxtmi.com/caselaws?id=468703 Receipts from management services were held not taxable as fees for technical services because the services were rendered under a separate management agreement and were distinct from the licence arrangement covering royalty and technical assistance. The existence of related agreements for patents, trademarks, copyrights and know-how did not convert management support into treaty-based technical services. On the India-Singapore treaty issue, the services in the relevant year were materially similar to earlier years, and the make available requirement under Article 12(4)(b) was not satisfied. The addition was therefore deleted in favour of the assessee. en-us Tue, 21 Nov 2023 00:00:00 +0530 Mon, 18 May 2026 15:14:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468703 Receipts from management services were held not taxable as fees for technical services because the services were rendered under a separate management agreement and were distinct from the licence arrangement covering royalty and technical assistance. The existence of related agreements for patents, trademarks, copyrights and know-how did not convert management support into treaty-based technical services. On the India-Singapore treaty issue, the services in the relevant year were materially similar to earlier years, and the make available requirement under Article 12(4)(b) was not satisfied. The addition was therefore deleted in favour of the assessee. Case-Laws Income Tax Tue, 21 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468703