person rendering the services
even if the foreign recipient of the services utilizes
the benefit of such services in India.”
As is clear from ... various stages. The second mentioned services may be
considered as services rendered in India. But, definitely
the other services rendered and informed to the other
towards
management services fees to be in nature of fees for Technical
services („FTS‟) in terms of Article 13 of India-France Double Tax
Avoidance ... Services
Agreement is managerial services. It is plain that once the
expression "managerial services" is outside the ambit of "fee for
technical
Article 12 ( Fee for
Technical Services) of the India Singapore DTAA, the services
should first be of technical or managerial or consultancy ... ascertaining the character of the services whether the
same are "routine support services" or "technical, managerial or
consultancy", before the lower
Petitioner fell within the purview of Royalty/ Fees for Technical
Services (hereinafter, referred to as „FTS‟) and is liable to be taxed under
section 44DA ... rendering of any managerial,
technical or consultancy services (including the provision of
services of technical or other personnel) but does not include
consideration
such services are 'made
available' to the services. In this regard, it is stated that the referral
services/other services are provided only ... referral services/other services are provided to support Surf
Gold in carrying on its business. These services do not make available any
technical knowledge, skill
nature of technical or consultancy services
and
2. Services should make available technical knowledge, experience,
skill knowhow or processes to the recipient of services ... considered
that out of the above services, few services may be considered as
technical or consultancy services, the same would still be not taxable
under
interconnection usages charges (IUC) is in the nature of fees for technical
services and whether the assessee is liable for TDS under s.194J ... appellant to other telecom companies are not
covered under fees for technical services and out of the purview of TDS
provision of 194J
basic design and engineering 6.650
3.5.1.1 [v] technical services for Project 1.000
management like planning,
procurement, inspection,
expediting, etc.
3.5.1.1 [vi] As built drawings ... with Essar Ltd. to associate the former as a technical consultant to
render technical services in relation to implementation of a project
Abbey
National Plc, UK, can be categorized as 'fees
for technical services' under Section ... rendering of any
16
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 ... observed that 'technical services' like
'managerial' and 'consultancy' services would denote seeking services to
cater to the special needs
