Indian decision that fees for (interior) designs or drawings do not constitute technical service fees or royalty under India-Singapore tax treaty

The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling in the case of The Indian Hotels Company Ltd. v. Income Tax Officer (unreported) dealing with the issue of whether fees payable to a foreign company for carrying out interior designing constituted "fees for technical services" (FTS) or "royalty" under the India-Singapore tax treaty (the tax treaty).
(a) Fac…
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