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5598/Mum/2016 commission etc. in respect of GDR issue was not income by way of fees for technical services because although the lead managers ... rendered technical, managerial or consultancy services for bringing out the GDR issue, such services are not made available to the assessee in as much

issue of Global Depository Receipts for which they are entitled for remuneration. The Tribunal found that the services of the managers for issue of Global ... outside India, the service of managers are enjoyed. The decision to issue GDR was taken by Indian company without any assistance from managers

company to a non-resident in connection with Public Issue of Global Depository Receipts (GDR) for services rendered outside India. The question before the Tribunal