Mobilisation / demobilisation charges cannot be treated as Royalty

An order dated 15th February 2012 passed by the Authority for Advance Rulings (‘AAR’) (Income Tax) in AA No. 936 of 2010 has been challenged in this writ petition filed by Technip Singapore Pte Ltd. (formerly known as Global Industries Asia Pacific Pte. Ltd.), a company incorporated in Singapore. The Petitioner, a resident of Singapore, is admittedly entitled to the benefit of India-Singapore Double Tax Avoidance Agreement (hereinafter „DTAA‟). Background facts The Petitioner states that it is a leading solutions provider of offshore construction, engineering, project managemen...