https://www.taxtmi.com/caselaws?id=795926 Article 12(4) of the India-Singapore tax treaty treats research management support fees as fees for technical services only where technical knowledge, experience, skill, know-how or processes are made available, or a technical plan or design is transferred. Continued year-on-year dependence on the provider indicates that the recipient cannot independently perform the services, and incidental advisory, managerial or technical benefits do not meet the make-available test. The notes state that, absent an Indian permanent establishment, such fees are not taxable in India. They also identify retrospective limitation provisions as governing assessment timeliness. en-us Wed, 15 Jul 2026 00:00:00 +0530 Wed, 29 Jul 2026 08:21:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795926 Article 12(4) of the India-Singapore tax treaty treats research management support fees as fees for technical services only where technical knowledge, experience, skill, know-how or processes are made available, or a technical plan or design is transferred. Continued year-on-year dependence on the provider indicates that the recipient cannot independently perform the services, and incidental advisory, managerial or technical benefits do not meet the make-available test. The notes state that, absent an Indian permanent establishment, such fees are not taxable in India. They also identify retrospective limitation provisions as governing assessment timeliness. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795926