Receipt towards re-fabrication of bushing not taxable under Article 12 of Indo-Singapore tax treaty
ITAT Mumbai held that charges received for carrying out of re-fabrication of bushing doesn’t tantamount to ‘make available of technical knowledge, experience, skill, know-how or process’ and hence cannot be taxed under Article 12 of Indo-Singapore tax treaty.
United States United States Oc Inc Owens Corning Inc Oc Technology License Agreement Owens Corning Group Of Company Technical Services
Source: taxguru.in