No addition on account of royalty in absence of technical knowledge, skill in terms of Article 12(4)(b) of India-Singapore DTAA

HP Services [Singapore] PTE Ltd Vs DCIT (ITAT Delhi) Conclusion: Receipts from providing information technology related support services could not be considered as royalty and/fees for technical services as while running the services, assessee had not made available any technical knowledge, experience, skill in terms of Article 12(4)(b) of the DTAA and as such, receipts in question were not FTS liable to tax in India. Held: In the present case, AO treated receipts from providing information technology related support services considered as royalty and/fees for technical services. The underlyin...