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Documents citing Us Technology Resources Pvt vs The Commissioner Of Income Tax on 13 December, 2018

The Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

The Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

The Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

The Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

The Commissioner Of Income Tax ... vs Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

The Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document

The Commissioner Of Income Tax ... vs M/S Expeditors International Of ... on 13 February, 2025

91. Of equal significance are the observations of the Kerala High Court in US Technology Resources [US Technology Resources (Pvt.) Ltd. v. CIT, (2018) 407 ITR 327 (Ker); 2018 SCC OnLine Ker 3113.] when their Lordships laid emphasis on the transfer of Signature Not Verified Digitally Signed By:KAMLESH KUMAR ITA 202/2022 & Connected Matters Signing Date:17.02.2025 Page 17 of 22 14:23:05 technology or know-how being a necessary ingredient of the "make available " condition which stands indelibly attached to fees for technical services. To recall, the Kerala High Court in the aforenoted decision had held (page 338 of 407 ITR):
Delhi High Court Cites 21 - Cited by 0 - Y Varma - Full Document
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