Case Law Analysis
|Income Tax Appellate Tribunal
India-Singapore DTAA | 'Make Available' Condition Mandatory for FTS Taxability Under Article 12(4)(b) : ITAT Mumbai
ITAT Mumbai holds that management support services do not qualify as Fees for Technical Services (FTS) under the India-Singapore DTAA unless the 'make available' condition is satisfied, clarifying the taxability of cross-border service fees for multinational enterprises. The ruling reinforces the need for technical knowledge transfer to trigger FTS taxation under tax treaties.