ITAT Remands Case for Re-examination of Taxability of Management Service Fees Under India-Singapore Tax Treaty.

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....The Income Tax Appellate Tribunal (ITAT) examined the taxability of income in India regarding management service fees. For quality development and training services, the assessee offered the income to tax, conceding transfer of know-how and technology. Regarding information technology services, the CIT(Appeals) concluded that the fee was not taxable in India as the 'make available' criteria under the India-Singapore tax treaty was not satisfied. For other services like planning analysis/corporate development, human resources, and finance, the CIT(Appeals) upheld the addition solely on the ground that the assessee did not furnish complete details to determine the exact nature of services. The assessee contended that relevant documents were f.........