Assessee to entities resident in India is "fees for technical services"
within the meaning of Explanation 2 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
from April 1, 1989, payment in
respect of royalty, fees for technical services or other sums
chargeable under the Income-tax Act would ... remitted outside India come within the definition of
royalty or fees for technical service or other sums chargeable
under the Income-tax Act then
crores and odd in the shape of fees for technical services. This
type of comparison made by the TPO for determining that ... here
submitted that the purpose of making technical fee payments was to obtain
access to technology and services that went to the establishment
segregation of the transaction
including inter alia royalty and fee for technical services, was not
permissible in the circumstances of the case.
4. The facts ... Gruner AG towards licensing of
its brand and also for supply of technical know-how. These were
ITA 708/2016 Page 1 of 7
evidenced
These provided that
persons for all the services other than architect service and the barrack and
store services were to be recruited through competitive exams ... instruction created Engineer Services under the
Engineer-in-Chief. Consequently, the Military Works Services were
designated as the Military Engineer Services (MES). Its control
place, vis-à-vis its competitors, in regard to the goods
or services it trades or deals in. The expression is broadly defined in that ... services. It
further goes on to include any limits/restrictions on production of goods or
provision of services or market therefore; or limiting/restricting technical
My Space Inc. vs Super Cassettes Industries Ltd. on 23 December, 2016
Bench: S. Ravindra
character, that is to
say, not capable of distinguishing the goods or services of one person from
those of another person" [ Section ... rendering of the service or other characteristics
of the goods or services" [ Section 9 (1) (b) ]; those consisting exclusively of
FAO (OS) 403/2012
trade mark or similar property ;
(iv) the imparting of any information concerning technical,
industrial, commercial or scientific knowledge, experience or
skill ... distribution or
exhibition of cinematographic films ; or
(vi) the rendering of any services in connection with the
activities referred to in sub-clauses
circuit, strictly in
conformity with the requirements of the F1 Sporting and Technical Regulations and the
FIA Sporting Code. Therefore, the grant of Formula ... which held that if a contract for the supply of
goods and services also permits "incidental use" of trademarks, logos and other
