https://www.taxtmi.com/caselaws?id=793492 Receipts from credit rating and annual surveillance services were analysed under Article 12 of the India-Singapore DTAA and were found not to be taxable as royalty or fees for technical services. The decisive test was whether the services made available technical skill, know-how, expertise, process, or commercial experience to the client. Because the material showed only rating and surveillance functions, with no imparting of underlying technical knowledge or right to use qualifying information or skill, the treaty conditions were not met. On that reasoning, the article states that the receipts were outside the royalty/FTS provisions and the corresponding addition was deleted. en-us Mon, 15 Jun 2026 00:00:00 +0530 Wed, 17 Jun 2026 07:46:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793492 Receipts from credit rating and annual surveillance services were analysed under Article 12 of the India-Singapore DTAA and were found not to be taxable as royalty or fees for technical services. The decisive test was whether the services made available technical skill, know-how, expertise, process, or commercial experience to the client. Because the material showed only rating and surveillance functions, with no imparting of underlying technical knowledge or right to use qualifying information or skill, the treaty conditions were not met. On that reasoning, the article states that the receipts were outside the royalty/FTS provisions and the corresponding addition was deleted. Case-Laws Income Tax Mon, 15 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793492