No income tax on Revenue from IDC/Management /Referral Agreement under India-Singapore DTAA

Edenred Pte Ltd Vs DDIT (ITAT Delhi) The issue under consideration is whether income tax levied on revenue received from IDC agreement, management agreement, and referral agreement as per the India-Singapore DTAA? In the present case, during the assessement the AO, after incorporating the direction of the DRP passed a final assessment order by taxing (i) IDC charges as royalty as per provisions of the Act and the India-Singapore DTAA, (ii) management charges as Fees for Technical Services (‘FTS’) as per provisions of the Act and the India-Singapore DTAA and (iii) referral fees as r...