S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Singapore based company-Business of providing/sub-licensing software and earned revenue from maintenance services and training services provided to its Indian customers-Income of assessee from rendering said services would not fall within ambit of FTS and was not taxable in India-DTAA-India-Singapore. [S. 9(1)(vi), Art. 12]
DCIT (IT) v. Murex Southeast Asia (P.) Ltd. (2025) 212 ITD 592 (Mum) (Trib.)