rendering of any managerial, technical or consultancy services
(including the provision of services of technical or other personnel) but
does not include consideration ... rendering of any managerial, technical or consultancy services
(including the provision of services of technical or other personnel) but
does not include consideration
expenses, if any, incurred in foreign
exchange in providing the technical services outside India;
ITA 551/2013 & 553/2013 Page ... exchange in providing technical services
outside India. The services must be provided by the assessee, i.e. in
respect of services provided by the assessee
rendering of any managerial, technical or consultancy services
(including the provision of services of technical or other personnel) but
does not include consideration ... rendering of any managerial, technical or consultancy services
(including the provision of services of technical or other personnel) but
does not include consideration
associate Met Chem
Canada Inc. as a technical consultant to render technical services in
relation to implementation of a project to set up a plant ... consultant shall render following engineering
and other technical Services from outside India;
2.1.1. Project Engineering Services:
Technical Consultant shall act as technical coordinator
rendering of any managerial,
technical or consultancy services (including the provision of
services of technical or other personnel) but does not include
consideration ... services, we mean in this context services
requiring expertise in technology. By consultancy services, we
mean in this context advisory services. The category of
technical
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
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
along with warranty and tax, there was no
technical assistance by providing managerial, consultancy or technical
services. It concluded that Technik performed the entire work ... technical services, we mean in this context services
requiring expertise in technology. By consultancy services, we
mean in this context advisory services. The category
Panalfa Autoelecktrik (supra), this Court observed that technical
services consist of services of technical nature "when special skills or
knowledge relating to technical field ... maintained by PGCIL through its technical personnel using technical
expertise. This, however, does not result in PGCIL providing technical
services to DTL. Therefore the wheeling
order that the placement fee should be
treated as Fees for technical services for the purpose of
TDS under section 194J ... nature of 'fees for technical services'
because any services of managerial, technical or
consultancy nature were not rendered by the cable
operators! MSOs
