Disaster recovery playout services and up-linking services are not in nature of FTS under India-Singapore DTAA

Planetcast International Pte Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that receipts from disaster recovery playout services and disaster recovery up-linking services are not in the nature of Fee for Technical Service (FTS) as envisaged under Article 12(4)(a) of India-Singapore DTAA. Facts- The assessee has challenged the taxability of receipts from provision of disaster recovery up-linking services and disaster recovery play-out services as fee for technical services (FTS) under section 9(1)(vii) of the Act and Article 12(4) of India-Singapore DTAA. Without prejudice to the addition made as ro...