Case Law Analysis
|Income Tax Appellate Tribunal
Section 9(1)(vii) & India-Singapore DTAA | Project-Specific Design Services Not Taxable as Fees for Technical Services : ITAT Mumbai
ITAT Mumbai rules that payments for project-specific architectural and structural design services to Singapore entities do not qualify as Fees for Technical Services under the India-Singapore DTAA, exempting them from TDS under Section 195. The ruling clarifies the scope of FTS, preventing disallowance under Section 40(a)(i) for real estate developers and similar businesses.