Technical Services Rendered Do Not Qualify as Fees for Technical Services Under India-Singapore Tax Treaty Provisions

ITAT adjudicated a dispute concerning taxability of technical services under India-Singapore DTAA. The tribunal analyzed whether maintenance and training services constituted Fees for Technical Services (FTS). After comprehensive examination of service agreements, ITAT determined that the services did not transfer technical skills or expertise enabling technology application. Consequently, the income derived from such services was deemed non-taxable in India. The tribunal ruled in favor of the assessee, rejecting revenue's contention of taxable income, thus precluding tax liability under the bilateral tax treaty's provisions. .....

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