India-Singapore DTAA – Fee paid to AXA ARC by applicant for receiving assistance such as business support, marketing information technology support services and strategy support etc., does not amount to fee for technical services within meaning of India – Singapore Tax Treaty

CASE LAWS DETAILS DECIDED BY: AUTHORITY FOR ADVANCE RULINGS (INCOME TAX), NEW DELHI, IN THE CASE OF: Bharati AXA General Insurance Co. Ltd., In re , APPEAL NO: A.A.R. No. 845 of 2009, DECIDED ON AUGUST 6, 2010 9. The definition of FTS as contained in clause (b) of Article 12.4 is explicitly designed to restrict the scope and ambit of the technical and consultancy services. Even if we proceed on the basis that some of the services have the flavour of imparting technical knowledge and experience to the recipient of service, the further question is whether such provision of services enables the p...