The Tribunal held that the payments received by the assessee from RCITP are fees for technical services falling under cl. (4) of art. 12 of the DTAA, rightly taxed at 10 per cent. (AY. 2016-17)
Gensler Singapore (P) Ltd. v. JCIT /(2023) 155 taxmann.com 207/ 37 NYPTTJ 1293 / (2024) 227 TTJ 998 / 234 DTR 193 (Delhi)(Trib)
S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Interior design services-Payments received by the assessee from RCITP are fees for technical services falling under cl. (4) of art. 12 of the DTAA-DTAA-India-Singapore [S.90, 144C(5), 144(13), Art. 12]