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Global Account Management charges and Leaseline charges received by assessee were reviewed for tax classification. HC held that management charges qualify as Fees for Technical Services/Included Services (FTS/FIS) under Section 9(1)(vii), while Leaseline charges constitute Royalty under Section 9(1)(vi). Regarding Freight Logistic Support services, HC determined these do not qualify as FTS/FIS since customs clearance rules are publicly available information, not specialized knowledge. The court emphasized that FTS requires both specialized expertise and "make available" conditions where recipient gains independent capability. Creation of global workforce standards also did not meet FTS criteria. Software development aspects were addressed per Engineering Analysis Centre precedent. Appeal dismissed against revenue.
Global Account Management charges and Leaseline charges received by assessee were reviewed for tax classification. HC held that management charges qualify as Fees for Technical Services/Included Services (FTS/FIS) under Section 9(1)(vii), while Leaseline charges constitute Royalty under Section 9(1)(vi). Regarding Freight Logistic Support services, HC determined these do not qualify as FTS/FIS since customs clearance rules are publicly available information, not specialized knowledge. The court emphasized that FTS requires both specialized expertise and "make available" conditions where recipient gains independent capability. Creation of global workforce standards also did not meet FTS criteria. Software development aspects were addressed per Engineering Analysis Centre precedent. Appeal dismissed against revenue.
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