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
assessee to
OTOs as falling within the expression "fee for technical services (FTS)" in
terms of Explanation 2 to section ... rendering of any managerial, technical or consultancy services (including
the provision of services of technical or other personnel) but does not include
consideration
assessee to
OTOs as falling within the expression "fee for technical services (FTS)" in
terms of Explanation 2 to section ... rendering of any managerial, technical or consultancy services (including
the provision of services of technical or other personnel) but does not include
consideration
assessee to OTOs as falling within the
expression "fee for technical services (FTS)" in terms of Explanation 2 to section ... rendering of any managerial,
technical or consultancy services (including the provision of services of technical or other
personnel) but does not include consideration
assessee to OTOs as falling within the
expression "fee for technical services (FTS)" in terms of Explanation 2 to section ... rendering of any managerial,
technical or consultancy services (including the provision of services of technical or other
personnel) but does not include consideration
assessee to OTOs as falling within the
expression "fee for technical services (FTS)" in terms of Explanation 2 to section ... rendering of any managerial,
technical or consultancy services (including the provision of services of technical or other
personnel) but does not include consideration
assessee to OTOs as falling within the
expression "fee for technical services (FTS)" in terms of Explanation 2 to section ... rendering of any managerial,
technical or consultancy services (including the provision of services of technical or other
personnel) but does not include consideration
software development 112804278
and support services
Covansys Belgium NV Export of software development 25352418
and support services
TNMM
Covansys Export of software development 28154191
Deutschland ... software development 596207
and support services
Covansys S L. Spain Export of software development 11083994
and support services
Covansys Netherland Export of software development
rendering of any managerial, technical or consultancy services
(including the provision of services of technical or other personnel)
but does not include consideration ... technical services" which includes specialized services like
13
ITANo.448 & 449/Ind/2019
Sanp Computer Systems Pvt. Ltd
managerial, technical and consultancy
Sales & marketing expenses 2,26,70,845/-
14 Technical Services & Support Cost 9,37,14,421/-
Page ... royalty payment for technical know-now under royalty
agreement which covers all the payments including payment of technical
services provided
