into technical assistance know-how agreement with MBDL in India
for transfer of glass technology know-how. The assessee received technical
know-how fees ... view that the fee paid to
the AXA ARC by the applicant does not amount to fee for technical services within the meaning of
India
liable to sex in India as
both royalty and fee for technical/included services ('FTS/FIS') und the
provisions ... liable to sex in India as
both royalty and fee for technical/included services ('FTS/FIS') und the
provisions
holding the sum of Rs. 10,76,69,690 as 'Fees for technical services' under
Section 9(1)(vii) of the Act read ... DTAA, (vi) therefore, the fees
paid to AXA ARC by the applicant does not amount to fees for technical services
within the meaning
which arises for consideration is, whether the
subscription fee can be treated as fees for technical services. As discussed earlier, it is
evident that ... aforesaid view of the matter, the subscription fee received cannot be considered as a
fee for technical services as well."
13. In the case
well as support and maintenance services as Fees for o Technical
Services/Fee for Included Services under Article 12 of the India ... towards support and
maintenance services (being, INR 58,90,308) as Fees for Technical Services /
Fee for Included Services without providing for any basis
should be brought to tax as fee for
technical services/ fees for included services and in
doing so, failed to appreciate:
(i) that the receipts ... from registration of domain name and other
services would fall under fees for technical services u/s 9(1)(vii) as
well as Article
downloading BIRs is not in the nature
of Royalty or fee for technical services. The AAR held that the
purchase of standardized reports publicly available ... commercial experience. The Commissioner sought to bring the
payments under royalty/fees for technical service for the reason
that the BIRs are copyright protected
income from royalty. The Ld. AO
however assessed it as Fees for Technical Services ("FTS") which was
affirmed by the Ld. Dispute Resolution
addition to ICANN, each Top-Level
Domain („TLD‟) is maintained and serviced technically by an
administrative organisation operating a registry.
(b) The Registry is responsible ... 2022
both parties. The Registries and Registrars usually charge an annual fee
for the service of delegating a domain name to a user and providing
