Architectural Services provided to Singapore Entity Taxable at 10% when DTAA Benefit is Available

Mantri Technology Constellations Pvt. Ltd. Vs DCIT (ITAT Bangalore) The issue under consideration is whether the architectural services provided to Singapore Entity taxable at 10% or 20% when the benefit of Double Taxation Avoidance Agreement (DTAA) is available? ITAT states that, Non-Resident —TDS—Rate of deduction—Beneficial provision of DTAA—Assessee in normal course of its business remitted payments to Company D which was a non-resident company, located in Singapore—Company D was not tax assessee in India—Tax relationship between two countries was regulated in terms of IndoSing...