rendering of any technical or consultancy
services (including through the provision of services of technical
or other personnel) if such services:
(a) are ancillary ... services include services in relation to frequent travelers and
assess to regeneration system. In case of assessee services rendered
predominantly include providing non-technical training
rendering of any technical or
consultancy services (including through the provision of services of technical
or other personnel) if such services :
(a) are ancillary ... fees
for technical services' under Article 12(4)(b ) does not cover
consultancy services unless these services are technical in nature
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
transfer of a technical
plan or technical design.
(x) Accordingly, it is not a mere rendering of technical
or consultancy services, but the requirement ... person in
consideration for rendering technical, consultancy services
through the provision of services of technical or other
personnel. It is observed that 'Walmart
rendering of any managerial,
technical or consultancy services (including the
provision of services of technical or other
personnel) but does not include consideration ... services" u/s 9(l)(vii)
of the Act
4.30. Similarly, the services for Faculty
Development and Professional Services ure si.io
technical
rendering of any managerial, technical
or consultancy services (including the provision of services of technical
or other personnel) but does not include consideration ... technical services in
nature or character. The services rendered in the course of rendering
agency services are essentially business services and to obtain the
business
Treaty
but also development and transfer of any technical plan or
technical design, Technical does not mean technological. It only
means specialized- the area ... rendering of any
manag erial, technical or consultancy services including
the provisions of services by technical or other p ersonnel
but does not include payments
services in the
nature of ITES. The services rendered are in the nature in the nature
of marketing support services and incidental technical services ... services in the
nature of ITES. The services rendered are in the nature in the nature
of marketing support services and incidental technical services
Treaty
but also development and transfer of any technical plan or
technical design, Technical does not mean technological. It only
means specialized- the area ... rendering of any
manag erial, technical or consultancy services including
the provisions of services by technical or other p ersonnel
but does not include payments
technical service. The revenue held that there is a technical
arrangement between two telecom companies for providing
roaming services to their customers which is possible ... techno logy or technical knowle dge of
person is made available to other and not where by using technical
systems, services are rendere
