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2012 (2) TMI 365 - AT - Income TaxFees for technical services Revenue treated transportation fees receivable as FTS u/s 9(1)(vii) Hongkong company engaged in the business of provision of supply chain management, including the provision of freight and forwarding and logistics services Held that:- In instant case, role of the assessee in the entire transaction was to perform only the destination services outside India by unloading and loading of consignment, custom clearance and transportation to the ultimate customer. In our opinion, it is too much to categorize such restricted services as managerial services. Further, use of computer in tracing the movement of the goods, though indirect, remote and not necessary, can not bring the payment for freight and logistics services within the purview of "technical services". Also, section 9(1)(i) cannot be invoked since assessee rendered "International services" outside India - Decided in favor of assessee.
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