https://www.taxtmi.com/caselaws?id=795926 Article 12(4) of the India-Singapore tax treaty treats services as fees for technical services only where technical knowledge, experience, skill, know-how or processes are effectively made available, or a technical plan or design is developed and transferred. Continuing research management support that leaves the recipient dependent on the provider does not meet this test; incidental advisory, managerial or technical benefit is insufficient. Accordingly, such fees are not taxable in India as fees for technical services where no permanent establishment exists. Retrospective limitation provisions governing assessments nevertheless apply, so the assessments are not time-barred. 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 services as fees for technical services only where technical knowledge, experience, skill, know-how or processes are effectively made available, or a technical plan or design is developed and transferred. Continuing research management support that leaves the recipient dependent on the provider does not meet this test; incidental advisory, managerial or technical benefit is insufficient. Accordingly, such fees are not taxable in India as fees for technical services where no permanent establishment exists. Retrospective limitation provisions governing assessments nevertheless apply, so the assessments are not time-barred. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795926