India-Singapore DTAA: Payments for design services in Singapore not subject to TDS, Article 12 inapplicable.

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....TDS Liablity - fees for technical services - payment of rArchitectural services and Interior designing and Architectural services - Since, we have held that the payments made to Singapore parties are not in the ‘nature of royalties or fees for technical services’, no purpose would be served by referring to Article 12 of India-Singapore DTAA - AT....