Assessee-company and Singapore based company had entered into architectural design services agreement in respect of residential projects in Chennai. Assessing Officer held that the assessee had availed technical knowledge, skill, know-how and therefore, payments made to non-resident company in Singapore were in nature of Fees for Technical Services (FTS) and was taxable. Tribunal remanded the matter to AO for verification. (AY. 2014-15)
Mantri Technology Constellations (P.) Ltd. v. DCIT (2020) 185 ITD 300/82 ITR 4 (SN) (Bang.)(Trib.)
S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Matter remanded-DTAA-India-Singapore. [Art. 12]