foreign company deriving income by way of royalty or fees for technical services received from Government or an Indian concern in pursuance of an agreement ... purposes of this clause and clause (6B),— (a) "fees for technical services" shall have the same meaning as in Explanation 2 to clause
securities; or (B) the interest, [dividend,] royalty or fees for technical services chargeable to tax at the rate or rates specified in Chapter ... securities; or (B) the interest, [dividend,] royalty or fees for technical services chargeable to tax at the rate or rates specified in Chapter
respect of consideration for supply
of technical information for use outside India and rendering
Technical Services to foreign Government Enterprise-Whether
`similar' to `royalty ... understood
to take within its fold all utilisation of technical
knowledge or rendering of technical services necessary to
bring about the construction, assembly and installation
income by way of fees for technical services payable by- (a) the Government; or (b) a person who is a resident, except where the fees ... rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration
expenses, if any, incurred in foreign exchange in providing the technical services outside India; [Substituted by Act 10 of 2000, Section 6, for Section
expenses, if any, incurred in foreign exchange in providing the technical services outside India; [Substituted by Act 10 of 2000, Section 7, for Section
subscription before the 1st day of April, 1938), royalty, fees for technical services or other sum chargeable under this Act, which is payable, (A) outside ... section (1) of section 9; (B) "fees for technical services" shall have the same meaning as in Explanation2 to clause (vii) of sub-section
Income Tax Act, 1961
194J. [ Fees for professional or technical services. [Inserted by Act 22 of 1995, Section ... fees for professional services, or (b) fees for technical services, ][or [ Inserted by Act 29 of 2006, Section 16 (w.e.f. 13.7.2006).] (c) royalty
India to a place outside India by any means; (ii) providing technical services outside India in connection with the development or production of computer software ... expenses, if any, incurred in foreign exchange in providing the technical services outside India;] [Inserted by Act 49 of 1991, Section
business of development and export of computer softwares and
rendering technical services.
(b) The Respondent has shown gross income from business ... Respondent, are nothing but in the nature of expenses incurred
for technical services provided outside India. Further, in view of
7
the fact that
