income arising out of shipping business and not as fees for
technical services?”
Similar question of law, according to the Revenue, arises in all these ... between the words “managerial and
consultancy services”.”
7. “Managerial and consultancy services” and, therefore, necessarily
“technical services”, would obviously involve services rendered by human
efforts
fees for technical services" as used in this Article
means any payment for the provision of services of managerial,
technical or consultancy nature ... individual for
independent personal services mentioned in article 15 , in
consideration for services of a managerial, technical or consultancy
nature, including the provision of services
rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration ... amount for specific services i.e. "Managerial, Technical or Consultancy". "Technical Services", therefore, as per Explanation (2) is not confined
Engineers India Technical Services ... vs Commissioner Of Central Excise & ... on 20 June, 2017
Bench: Thottathil B. Radhakrishnan , P. Sam Koshy
1
AFR
HIGH COURT ... BILASPUR
Tax Case No. 5 of 2014
M/s. Engineers India Technical Services, 221, 2 nd Floor Crystal Tower Lodhipara
Shankar Nagar Road, Raipur, Chhattisgarh
from 1.4.2011,
vide its Article 12.5 , provide that the fees for technical
services, if such services are rendered and paid in a
Contracting State ... fees for technical services
relate to services performed, within a Contracting
State, then such royalties or fees for technical
services shall be deemed to arise
Wipro Ltd vs Excise & Taxation Technical Services ... on 24 January, 2017
Author: Rakesh Kumar Jain
Bench: Rakesh Kumar Jain ... decision:24.01.2017
M/s Wipro Limited
.........Petitioner
versus
Excise and Taxation Technical Services Agency(ETTSA) and others
..........Respondents
Wipro Ltd vs Excise And Taxation Technical Services ... on 24 January, 2017
Author: Rakesh Kumar Jain
Bench: Rakesh Kumar Jain ... decision:24.01.2017
M/s Wipro Limited
.........Petitioner
versus
Excise and Taxation Technical Services Agency(ETTSA) and others
..........Respondents
Vishnu Manglani vs . Ms Iyogi Technical Services Pvt. Ltd. on 24 October, 2017
IN THE COURT OF ANIL ANTIL,
ADDITIONAL DISTRICT JUDGE 05 SOUTH EAST ... DELHI.
CS No. 398/17
Vishnu Manglani Vs. Ms Iyogi Technical Services Pvt. Ltd.
1. Vishnu Manglani
S/o Late Sh. Gurbakshrai Rai Manglani
Aged
receipts were taxable either as business income or
as fee for technical services (FTS). In these three appeals, however, the
Court proposes to confine ... Maintenance
(O&M) Agreements should be treated as fees for technical services („FTS‟)
within the meaning of Explanation 2 to 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 Explanation 2 to clause
