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We have not provided any technical or managerial services. We were only working as an interface to get order. All the work was done by the Snap Systems team by connecting to the clients' network using VPN (Virtual Private Network) and VDI (Virtual Desktop Image).

14. The above certificate makes the picture very clear that "SII" has only have acted as a Liaison and procurement agent between assessee and clients based in USA. SII was working only as an interface to procure orders and hand over the same to the assessee who in turn was to carry out the work through its team by connecting to the clients network using Virtual Private Network and Virtual Desktop Image. There remains no dispute to the fact that apart from the work of procurement orders for the assessee no other services were rendered by "SII". Software services were rendered by the assessee directly to the customers by logging in directly with the clients network. Though in the agreement the ITANo.448 & 449/Ind/2019 Sanp Computer Systems Pvt. Ltd payment is nomenclated as consulting services but it is only paid as a commission for procuring orders from the customers. "SII" has not rendered any service except directing the customers to the assessee for supply of software services. "SII" do not have any interface in supplying such services. There is no evidence to show that SII was having any role of providing technical services in the work performed between assessee and its clients. For getting the orders the agent normally gets commission and reimbursement of expenses on the basis of actual time spent. In short "SII" simply obtains the orders on the basis of nature of services to be provided by the assessee and nature of services required by the client. Once both these things are matched the orders are procured and communicated to the assessee who thereafter develops the software in India as per the need of the client. In view of the above discussions we are of the considered view that Non resident company M/s System Integration Inc. has not provided any technical services to the assessee and the alleged amount received by it were only for the commission and incidental expenses for liaison work and procurement order.