TMI Blog2008 (7) TMI 844X X X X Extracts X X X X X X X X Extracts X X X X ..... see, being an Indian company or a person other than a company who is resident in India, includes any income received by the assessee from the Government of a foreign State or foreign enterprise in consideration for the use outside India of any patent, invention, design or registered trade # Portions apprived for reporting aline are printed here-Ed. mark and such income is received in convertible ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l or consultancy services (including the provision of services of technical or other personnel) but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head `Salaries'." As per Explanation 2 to section 9(1)(vii), rendering of any managerial, technical or cons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aring experience for running the factory as also for improving and developing technical and managerial skills of its personnel as also to participate in the practical application of the planned technology. On the ground that providing of such technical assistance would entitle the petitioner to claim deduction under section 80-O of the Income-tax Act, an application was filed for approval of the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ided by the assessee that it actually rendered certain technical services. The assessee has in fact provided copies of the technical service agreement entered into by the assessee-company with the foreign enterprises and it is an admitted fact that its technical service agreements have been approved by the Central Board of Direct Taxes/Chief Commissioner of Income-tax. While so it is not proper to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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