Receipt of architectural design services cannot taxed as FTS or Royalty

DCIT Vs Aedas Pte. Ltd. (ITAT Delhi)

ITAT Delhi held that the payments received by the assessee in view of architectural design services rendered to its clients in India are not chargeable to tax as FTS in terms of Article 12(4) of the India-Singapore DTAA.

Facts- The assessee is a company incorporated under the laws of Singapore and is a tax resident of Singapore. The assessee is engaged in the profession of rendering project specific architectural design services. The architectural designs provided

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