Amount, not qualifying as royalty or FTS, not taxable under Article 12(2) of India-Singapore DTAA

Atos Information Technology Singapore Pte Ltd Vs DCIT (ITAT Mumbai) Facts- The assessee is incorporated in Singapore and is also a tax resident of that country. As stated by the AO, during the year under consideration the assessee had provided certain services to its group concern in India, viz. Atos India Pvt Ltd (Atos India) and received payment. The assessee didn’t offer the payment as income. Accordingly, AO called upon the assessee to explain as to why the payment received from the Indian group concern should not be treated as royalty/ FTS and made taxable in India. Conclusion- Applying...