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Showing contexts for: Sample flat in M/S. Macrotech Developers Ltd (As ... vs Income Tax Officer (It) 3 (2) (2) , Mumbai on 24 January, 2023Matching Fragments
ITO (IT)-3(2)(2) Vs. M/s Macrotech Developer Ltd.
interior planning and designing, sales office colour schemes, furnishing selections, in Dubai.
material and decorative specifications,
indoor plants designing and Such
recommend indoor planters for the services are
project sales office and sample flat. not table as
HBA provides its report detailing 'Fees for
above mentioned specification. As a Technical
marketing strategy, every business Services'
would try to distinguish its project since the
from other products available in the services do
market by offering some unique not meet
features. Similarly, the management 'Make
of Company decided to bring available'
international expertise in India to offer Criteria.
unique and different product to the
customers. The services provided by
HBA Designs are so unique and
project specific which cannot be
performed by anybody and everybody
unless such person is in possession of
specific skill set and knowledge
3. Windtech Australia Windtech had provided wind climate Wind climate
Consultant analysis services for the Washington Analysis
Pty. Ltd. House project. This inter-alia includes Consultancy
analyzing and testing the blow of the Service Such
wind in the area where the project is services are
being developed and the impact it has not taxable
on the building. Windtech provides its under India-
analysis and conclusion in the form of Autralia
a report along with corrective DTAA in
measures if required. The services absence of
provided by windtech are so unique specific
and project specific which cannot be provision
performed by anybody and everybody dealing with
unless such person is in possession of taxability of
specific skill set and knowledge. 'Fees for
Technical
Services'.
The
provisions of
the DTAA
being more
beneficial,
have been
applied.
4. KPMG United United KPMG UK had provided tax and Tax Advisory
Kingdom PLC Kingdom regulating advisory services to the and
company for with respect o its Consultancy
expansion of its business in the UK. Services.
The Company was explain UK Real
Estate market in the FY 2014-15 and Such
for this purpose it has approached services are
KPMG UK to provide tax and not taxable
regulartory advisory services in as 'Fees for
relation to the prposed activities. The Technical
services provided by KPMG UK Services'
aretechnical in nature and are with since the
respect to the specific query asked by services do
the Company. The advisory provided not meet
by KPMG UK are technical in nature 'make
and cannot be performed by anybody available'
and everybody unless such person is criteria.
in possession of tax and regulatory
knowledge.
P a g e |6
4 Appeals