https://www.taxtmi.com/caselaws?id=801051 Article 12(4)(b) of the India-Singapore tax treaty treats technical, managerial or consultancy services as fees for technical services only where they make available technical knowledge, experience, skill, know-how or processes for independent use by the recipient. Recurring software maintenance, remote support, bug resolution, standard updates and user training do not meet that condition where customers remain dependent on the service provider. Software migration from an old version to a new version likewise does not qualify without transfer of independent technical capability. Such receipts are business receipts and are not taxable in India absent a permanent establishment. en-us Thu, 17 Sep 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801051 Article 12(4)(b) of the India-Singapore tax treaty treats technical, managerial or consultancy services as fees for technical services only where they make available technical knowledge, experience, skill, know-how or processes for independent use by the recipient. Recurring software maintenance, remote support, bug resolution, standard updates and user training do not meet that condition where customers remain dependent on the service provider. Software migration from an old version to a new version likewise does not qualify without transfer of independent technical capability. Such receipts are business receipts and are not taxable in India absent a permanent establishment. Case-Laws Income Tax Thu, 17 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801051