ITAT Holds Service Receipts Not Taxable as FTS under India-Singapore DTAA due to Lack of Knowledge Transfer

The ITAT has held that service receipts are not taxable as Fees for Technical Services (FTS) under the India-Singapore DTAA due to a lack of knowledge transfer. The tribunal ruled that the services in question did not involve the transfer of technical knowledge, a key requirement for FTS taxation under the DTAA. This decision clarifies the interpretation of FTS provisions in tax treaties and provides guidance for cross-border transactions.