like MSETCL and PGCIL should have been
treated as fees for technical services and tax should have
been deducted at source u/s.194J ... rendering of any managerial, technical or
consultancy services (including the provision of services of
technical or other personnel) but does not include consideration
2015 21:09:51 :::
ITXA1306.13.doc
consideration / fees for technical services rendered by the assessee
and, accordingly, held them to be taxable ... manner, amount to rendering of any technical services.
6. Mr. Kaka, the learned senior counsel appearing on behalf of the
assessee pointed out that
Court in the case of Bharat
Aluminium Company Vs. Kaiser Aluminium Technical Services
INC. , reported in (2012) 9 SCC 552 and invited my attention ... Court in the
case of Bharat Aluminium Company Vs. Kaiser Aluminium Technical
Services INC. (supra) and would submit that the Supreme Court in the
said
Pol India Projects Ltd vs Aurelia Reederei Eugen Friederich Gmbh ... on 8 April, 2015
Author
machinery were not in the nature of fees for
rendering technical services and, therefore, the tax
deductible at source on these payments were covered under ... contract for services' implies a
contract whereby one party undertakes to
render services e.g. professional or technical
services, to or for another
therefore, was
eligible for appointment as an Extension Officer
[Agriculture], District Technical Services, Class-III.
Petitioner was appointed as an Extension Officer
[Agriculture] Grade
paragraph 17),
2) M.D. Army Welfare Housing Organisation vs. Sumangal Services
(P) Ltd. (2004) 9 SCC 619 (paragraphs 57 and 58),
3) Sundaram Finance ... adoption of Model Law,
9) Bharat Aluminium Company vs. Kaisar Aluminium Technical
Services INC. (2012) 9 SCC 552.
(vii) Under section 5 of the Arbitration
Bharat Aluminium Co. & Ors. vs. Kaiser Aluminium Technical
Services Inc. & Ors.1, (BALCO) would not apply and the matter
would be governed
CEXA.179-14.doc
experienced members drawn from the Revenue or Technical Services and
Judiciary are expected to perform this task efficiently. They are selected
paragraph 17),
2) M.D. Army Welfare Housing Organisation vs. Sumangal Services
(P) Ltd. (2004) 9 SCC 619 (paragraphs 57 and 58),
3) Sundaram Finance ... adoption of Model Law,
9) Bharat Aluminium Company vs. Kaisar Aluminium Technical
Services INC. (2012) 9 SCC 552.
(vii) Under section 5 of the Arbitration
