Non-resident corporate assessee's receipts for maintenance, ...

Software migration services receipts not taxable as FTS under India-Singapore treaty.

January 18, 2025

Case Laws Income Tax AT

Non-resident corporate assessee's receipts for maintenance, support, training services, and additional services relating to software migration held not taxable as Fees for Technical Services (FTS) under India-Singapore DTAA. Services did not make available technical knowledge or skills to recipient on a recurring basis. Assessee had no PE in India, so business receipts not taxable. ITAT allowed assessee's appeal.

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Non-resident corporate assessee's receipts for maintenance, ...

Software migration services receipts not taxable as FTS under India-Singapore treaty.

January 18, 2025

Case Laws Income Tax AT

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