that the words fees for technical services are wide enough to engulf services in the nature of managerial, technical or consultancy services. He also relied ... rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration
does not involve any technical knowledge or assistance in technical operations or other support in respect of any other technical matters. It also does ... technical knowledge, experience, expertise, skill or technical know-how of the processes involved or consist in the development and transfer of a technical plan
asset situate in India ; . . .
(vii) income by way of fees for technical services payable by
Provided that nothing contained in this clause shall apply ... rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration
held that it cannot be said that the assessee must provide technical services even where it receives consideration for only providing commercial information. The section ... proposition of law, that all managerial services must necessarily be non-technical services. It depends on the nature of the expertise required for rendering
Article
13(4) of the aforesaid agreement, the term “Fees for technical services”
means a payment of any amount ... person in consideration for rendering
of technical or consultancy services [including provision of services of
technical or other personal. It is therefore submitted that
Article 12 stood as follows:
1. Royalties, fees for technical services and payments for the use of equipment arising in one of the States ... Article 12 were modified as follows:
1. Royalties and fees for technical services arising in a Contracting State and paid to a resident
praying for the following judgment and decree:-
(a) declaration that the Technical Services Agreement dated 26.10.1988
and the Project Consultancy Agreement and Royalty Agreement both ... agreement, the first
plaintiff has agreed to provide its technical knowledge, skill and technical
services for the operation of the Hotel upon payment
manufacture of computer software' and the provision of
'technical services'?
(iv)Whether on the facts and in the circumstances of the
case ... customer
requirements, etc. and that
“software development”
will not amount to
“technical services” within
the meaning of Clause (iv)
to Explanation to Section
rendering of any managerial, technical or consultancy
services (including the provision of services of technical or other
personnel) but does not include consideration ... have been defined as managerial, technical or consultancy services
including the provision of services of technical or other personnel. But the
agreement in question does
rendering of any managerial, technical or consultancy
services (including the provision of services of technical or other
personnel) but does not include consideration ... have been defined as managerial, technical or consultancy services
including the provision of services of technical or other personnel. But the
agreement in question does
