Exclusion of Management Support Services from Article 12(4) of India-Singapore DTAA

Inter Continental Hotels Group [Asia Pacific] PTE Ltd Vs DCIT (ITAT Delhi) ITAT Delhi held that provision of management support services to various hotels in India doesn’t come under Article 12(4) of India -Singapore DTAA. Accordingly, addition unsustainable. Facts- The assessee has preferred the present appeal contesting that the CIT(A) erred in treating the amount received by the assessee from Inter Continental Hotels Group [Asia Pacific] India Pvt Ltd [IHGAP] towards provision of Management Support Services to be in the nature of Fees for Technical Services [FTS] under Article 12 of the I...