commercial rental any
copy of the computer programme". Thus, a distributor who purchases
computer software in material form and resells ... context of a computer programme, is to interdict
reproduction of the computer programme and consequent transfer of the
reproduced computer programme to subsequent acquirers
consultancy fee to Hindustan Computers Ltd_ in fact, the payment
was made for outright sale of 'computer software' which is used as
technique ... acquisition of technical know-
how is a capital expenditure, therefore, the assessing officer has
rightly treated the expenditure on acquiring the computer software
rendering of any technical or consultancy
services (including through the provision of services of technical
or other personnel) if such services:
(a) are ancillary ... services include services in relation to frequent travelers and
assess to regeneration system. In case of assessee services rendered
predominantly include providing non-technical training
Treaty
but also development and transfer of any technical plan or
technical design, Technical does not mean technological. It only
means specialized- the area ... rendering of any
manag erial, technical or consultancy services including
the provisions of services by technical or other p ersonnel
but does not include payments
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 in
nature or character. The services rendered in the course of rendering
agency services are essentially business services and to obtain the
business
services in the
nature of ITES. The services rendered are in the nature in the nature
of marketing support services and incidental technical services ... services in the
nature of ITES. The services rendered are in the nature in the nature
of marketing support services and incidental technical services
Treaty
but also development and transfer of any technical plan or
technical design, Technical does not mean technological. It only
means specialized- the area ... rendering of any
manag erial, technical or consultancy services including
the provisions of services by technical or other p ersonnel
but does not include payments
technical service. The revenue held that there is a technical
arrangement between two telecom companies for providing
roaming services to their customers which is possible ... techno logy or technical knowle dge of
person is made available to other and not where by using technical
systems, services are rendere
Services
Agreement is managerial services. It is plain that once the
expression 'managerial services' is outside the ambit of 'fee for
technical ... this context services requiring
expertise in a technology. By consultancy services, we mean in this
context advisory services. The categories of technical and
consultancy services
from
'maintenance services' as "royalty and fee for
technical services" under 9(1)(vi)/ (vii) of the
Income ... computer systems. For AY 2003-04, the Appellant filed its
return of income on March 22, 2005 wherein revenue classified
as fees for technical services
