rendering of any managerial, technical or consultancy services
(including the provision of services of technical or other personnel) but
does not include consideration ... between the words “managerial and consultancy
services”.
7. “Managerial and consultancy services” and, therefore,
necessarily “technical services”, would obviously involve services rendered
by human efforts
does not involve any technical knowledge or assistance in technical operations or other support in respect of any other technical matters. It also does ... technical knowledge, experience, expertise, skill or technical know-how of the processes involved or consist in the development and transfer of a technical plan
rendering of any managerial, technical or consultancy
services (including the provision of services of
technical or other personnel) but does not include
consideration ... between the words
―managerial and consultancy services‖.
7. ―Managerial and consultancy services‖ and,
therefore, necessarily ―technical services‖, would
obviously involve services rendered by human efforts
enabled services/BPO services primarily to
Citigroup entities globally. The operations of this company : 'broadly comprise
of transaction processing and technical services. Transaction processing ... Hospitality (TTH). It is providing services to BFSI and
TTH and such services include `Transaction processing' and `Technical
services'. In other words
services" takes colour
from the expressions "managerial services" and
"consultancy services" which necessarily involve a
human element. Since the services ... rendering of any managerial, technical or consultancy
services (including the provision of services of technical
or other personnel) but does not include consideration
nature of postage / courier
services or locker charges, therefore, such services are falling in the
nature of technical services. Therefore, the AO has rightly concluded ... account of client in electronic farm. These services cannot be said for
providing professional services or providing technical services, but the
charges are merely recovery
also effective connected with royalties an fee for
fee for technical services received from its 100% subsidiary Hyundai
Construction Equipment India (Pvt.) Ltd. (HCEIPL), Pune ... conveyers for Services u/s 115A
Nissan India
Line (import
services)
TCF Shorting 2,60,00,000 Yes; as Fee for Technical
Services
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 for technical or
5 ITA No. 2361/Mum/2015
certification, which
was technical in nature, and therefore, the impugned payment fell in
the category of 'fees paid for technical services'. The Assessing ... available any technical expertise
to the assessee so as to classify the impugned payment to HRD as "fees
for technical services
services provided by the tax payer of the A.E. are in the nature
of market support services, managerial services and even technical
support ... support services to ASL. He submitted that aTSPL is engaged in provision
of support services to aSL in connection with sourcing services to its adidas
