Services without transfer of any technical knowledge doesn’t qualify as FTS: ITAT Mumbai

Murex Southeast Asia Pvt. Ltd. Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that receipts from maintenance and support services and additional services, without transfer of any technical knowledge, know-how, skill, etc., are not in the nature of Fee for Technical Services (FTS) and hence not taxable in India.

Facts- The assessee is a non-resident corporate entity incorporated under the laws of Singapore and is a tax resident of Singapore. As stated by the Assessing Officer, the assessee is engaged in the business of providing/sublicensing software to entities in t

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