https://www.taxtmi.com/caselaws?id=798682 Regional support-service consideration does not constitute royalty under Article 12(3)(a) of the India-Singapore tax treaty or the Income-tax Act where the provider merely applies its own expertise and does not transfer proprietary information or grant a right to use industrial, commercial or scientific experience. Confidentiality restrictions reinforce the absence of any right of commercial exploitation. Such services also do not qualify as fees for technical services under Article 12(4)(b) unless they make technical knowledge, skill, know-how or processes independently usable by the recipient. In the absence of a permanent establishment in India, the receipts are business profits not chargeable to tax in India. en-us Mon, 07 Sep 2026 00:00:00 +0530 Thu, 10 Sep 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798682 Regional support-service consideration does not constitute royalty under Article 12(3)(a) of the India-Singapore tax treaty or the Income-tax Act where the provider merely applies its own expertise and does not transfer proprietary information or grant a right to use industrial, commercial or scientific experience. Confidentiality restrictions reinforce the absence of any right of commercial exploitation. Such services also do not qualify as fees for technical services under Article 12(4)(b) unless they make technical knowledge, skill, know-how or processes independently usable by the recipient. In the absence of a permanent establishment in India, the receipts are business profits not chargeable to tax in India. Case-Laws Income Tax Mon, 07 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798682