German AE was for receipt of technical
assistance for manufacturing of contract products while payment for
technical services ... relation to other component of project.
Therefore, the payments of technical royalty and technical services are
different, hence, no disallowance should be made. However
Inductotherm (India) Private Ltd., ... vs Dy.Cit.,Circle-2(1)(1), , Ahmedabad on 24 May
rendering
of any managerial, technical or consultancy services (including the
provision of services of technical or other personnel) but does not
include consideration ... should deduct tax
u/s.194J for technical services for the services provided "1) Support services
such as filed activations, vendor payment queries, entering
Shell Information Technology ... vs Dcit (It) 4(1)(2), Mumbai on 16 November, 2017
IN
payments received by the
assessee would qualify as "fee for technical services"as-defmed-
under section ... assessee from satellite transmission operations as
royalty/fee for technical services. The Ld. DRP also upheld the decision
of the Assessing Officer stating that
rendering of
any technical or consultancy services (including through the provision of
services of technical or other personnel) if such services :
(a) are ancillary ... technical knowledge, experience, skill, know-how, or processes or
consist of the development and transfer of a technical plan or technical design The
services provided
income arising out of shipping business and not as fees for
technical services?”
Similar question of law, according to the Revenue, arises in all these ... 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
this clause, the payments for rendering technical services, or
consultancy services, if such services make available technical
knowledge, experience, skill, know how or processes ... technical plan or technical design can
be charged to tax in India. In the case of the appellant the non
residents provided technical services
rendering of any managerial technical or
consultancy services (including the provision of services of technical or
personnel) but does not include consideration for any construction ... 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
country
services and out country services as per contract with Aker. The submission
of the assessee that its in country services are taxable ... fees for technical services under Article 13 of India-UK as these services
do not make available any technical knowledge, experience, skill, know
