https://www.taxtmi.com/caselaws?id=793606 The amended limitation regime under sections 144C, 153 and 153B was applied to the assessment, and the order was found to be within time, so the limitation objection failed. Management and business support fees received from an Indian subsidiary were held not to be fees for technical services under section 9(1)(vii) or Article 12(4) of the India-Singapore treaty because the arrangement involved support and coordination, not making available technical knowledge, experience, skill, know-how or processes, and no technical plan or design was transferred. The more beneficial treaty protection under section 90(2) prevailed, so the fee was not taxable in India as FTS. en-us Wed, 17 Jun 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793606 The amended limitation regime under sections 144C, 153 and 153B was applied to the assessment, and the order was found to be within time, so the limitation objection failed. Management and business support fees received from an Indian subsidiary were held not to be fees for technical services under section 9(1)(vii) or Article 12(4) of the India-Singapore treaty because the arrangement involved support and coordination, not making available technical knowledge, experience, skill, know-how or processes, and no technical plan or design was transferred. The more beneficial treaty protection under section 90(2) prevailed, so the fee was not taxable in India as FTS. Case-Laws Income Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793606