Tax leviable as receipt qualifies as Fees for Technical Services as per Indo – Singapore DTAA

Gensler Singapore Private Limited Vs JCIT (ITAT Delhi) ITAT Delhi held that payments received by the assessee qualifies as Fees for Technical Services (FTS) under sub-clause (4) of Article 12 of Indo – Singapore DTAA and hence rightly brought to tax @10%. Facts- The assessee is a tax resident of Singapore and is in the business of providing design services to customers in the Asia Pacific region. During the assessment year under consideration the assessee has provided the services to its Indian Associated Enterprises – Gensler Design India Pvt. Ltd. This service included designs, technical...