Receipt towards re-fabrication of bushing not taxable under Article 12 of Indo-Singapore tax treaty

Owens Corning (Singapore) Pvt. Ltd. Vs DCIT (ITAT Mumbai) ITAT Mumbai held that charges received for carrying out of re-fabrication of bushing doesn’t tantamount to ‘make available of technical knowledge, experience, skill, know-how or process’ and hence cannot be taxed under Article 12 of Indo-Singapore tax treaty. Facts- The assesssee is a company incorporated in Singapore and a group concern of Owens Corning Group of Company, which is a leading manufacturers of glass. The assessee is a tax resident of Singapore and has Associated Enterprises (AEs) namely Owens Corning India Pvt. Ltd. ...