called either to rendering of
technical services or managerial or consultancy services.
These different types of services were examined by the
Hon'ble Delhi ... resident to the respondent-
assessee. [Para 22]
The technical services consists of services of technical
nature, when special skills or knowledge relating to
technical field
services require technical or professional knowledge and the payments
were affected by the assessee to the respective parties for rendering
professional/technical services ... payments made for obtaining any managerial, technical or
consultancy services, as also for services of technical or other
personnel, which could be regarded as fees
ITGKs. He further
considered the word 'technical' with reference to fees for technical
services and held that payment made to ITGK ... definition of technical services in
Explanation 2 to sec. 9 l(vii), any services in consideration
of any managerial, technical or consultancy services was
covered
rendering of any managerial, technical or
consultancy services (including the provision of
services of technical or other personnel) but does not
include consideration ... words "managerial and
consultancy services".
7. "Managerial and consultancy services" and,
therefore, necessarily "technical services", would
obviously involve services
nature of brokerage and does not involve managerial and technical
services as per the provisions of Sec. 9(1)(vii) of the Act and explained ... technical or
managerial services. Apart from merely stating that the
services preformed were not in the nature of technical
services, the appellant firm
rendering of any technical or
consultancy services (including the provision of services of technical or other
personnel) which :
(a) are ancillary and subsidiary ... development and transfer of a technical plan or
technical design.
5. The definitions of fees for technical services in paragraph 4 of this article
shall
which subject 'royalties' and 'fees for technical
services' can be attributed. In terms of the India-Germany
DTAA, India does ... assessee has offered the royalties and
fees for technical services for taxability in India under art.
12 , and, to that extent, admitted tax liability exists
PSEB.
From the nature of services provided by payees, we find that the services
provided by payees are not technical in nature as defined ... rendering of any managerial, technical or consultancy services (including the
provision of services of technical or other personnel) but does not include
consideration
engaged in providing software technical services to
sole customer, viz., Fujitsu Services Ltd. The TPO has also narrated the
services rendered by this company which ... Hospitality (TTH). It is providing
services to BFSI and TTH and such services include `Transaction
processing' and `Technical services'. In other words
virtue of sophisticated and technically
advanced telecom equipments/machines and does not
require any human intervention for rendering of technical
services as defined in Explanation ... does not provide any technical service to
the home network operator so as to deduct TDS for rendering of
technical services within the ambit
