service maintenance charges and the testing and development
charges are not technical fees payable outside India.
12. For that the Commissioner of Income Tax (Appeals ... fee for use of a standard
facility provided to all those willing to pay for it does not amount to fee for technical
services
development and
transfer of a technical plan or technical design.
5. The definition of fees for technical services in paragraph 4 of this
Article shall ... make available technical knowledge, experience, skill or
know-how and / or process or development or transfer of any technical plan
or technical design
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
Deduction under section 10A of the Act.
2. Reduction of Technical Fees and Satellite Link Charges
from Export Turnover ... Ground No.2 is on the issue of reduction of technical fees
and satellite link charges from export turnover. AO while rejecting
the entire claim
granting rights to distribute Acronis software are in the
nature of fees for technical services (FTS) under the Act and
secondly, both ... appended to the draft assessment
order characterized the receipts as "technical service fee as
FTS", without furnishing any cogent reasoning or analytical
basis
agent. For these services the applicant charges subscription fee, system connects fee and helpdesk support fee, etc. The applicant opened a liaison office in Chennai ... permanent establishment. That subscription fee, system connect fee and helpdesk support charges cannot be treated as royalty or fees for technical services either under
Page 2 of 10
during the year under consideration as 'fees for technical services' as per the
provisions of Section ... development and transfer of a technical plan or
technical design.
5. The definitions of fees for technical services in paragraph 4 of this article
shall
treating the amount of expenditure on airfare booked under technical
guidance fee as capital, instead of revenue claimed by assessee.
3. On the facts ... only to payments of ―interest, commission or
brokerage, fees for professional services or fees for technical
services payable to a resident, or amounts payable
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
technical
services, which means any consideration (including any lump sum consideration) for
rendering of any managerial, technical or consultancy services (including the
provision of technical ... fees for technical services'. Further, rendering services by using
technical knowledge or skill is different than charging fees for technical
services. In the latter
