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2010 (8) TMI 8 - AAR - Income TaxService Agreement - Fees for technical services - cost plus method consideration - actual cost incurred plus a markup of 5% - various services such as Business Line Support, Reinsurance, Direct channel, claims, single actuarial organization and IT support services - DTAA - India-Singapore Treaty - Held that: - payments made to AXA ARC does not amount to 'fee for technical services' and 'royalty' within the meaning of Article 12 of the India-Singapore Tax Treaty. - There is no PE in India and payments received by it can not be taxes as business profits
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