TMI Blog2017 (5) TMI 1638X X X X Extracts X X X X X X X X Extracts X X X X ..... ons etc. - as held by the AO to be fee for technical services as per the provisions of the DTAA - Held that:- There was a service agreement drawn up and for providing such assistance between these two companies. It was essentially a joint venture. Having noted all the clauses in the agreement, the Tribunal rendered a finding of fact that there is no rendering of service within the meaning of the d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aj B. Darak for Respondent. JUDGMENT 1] We have heard Mr. Pinto appearing on behalf of Revenue in support of this appeal. In paragraphs 4.1 and 4.2 of this memo of appeal, the Revenue says that the facts are as under:- 4.1 The Assessing Officer, from the records noted that the Respondent Company had made payment of a sum of ₹ 4.83 crore, to Marks Spencer's PLC London, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 866187/- to M/S. Marks Spencer PLC towards salary expenditure of four employees deputed to the assessee for providing assistance in the area of management, to setting up of business, property selection and retail operations etc. There was a service agreement drawn up and for providing such assistance between these two companies. It was essentially a joint venture. Having noted all the clauses in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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