Management Support Fees Not FTS under India-Singapore DTAA: ITAT Delhi

Cameron (Singapore) Pte Ltd. Vs ACIT (ITAT Delhi) The article discusses the recent order from ITAT Delhi in the case of Cameron (Singapore) Pte Ltd. vs ACIT, addressing the assessment year 2016-17. The focus is on the contention that management support fees should not be treated as Fees for Technical Services (FTS) under Section 9(1)(vii) of the Income Tax Act, 1961, and Article 12(4) of the India-Singapore Double Taxation Avoidance Agreement (DTAA). Detailed Analysis: The appeal raised several substantive grounds, primarily challenging the AO’s decision regarding the nature of fees for ...