https://www.taxtmi.com/caselaws?id=66092 Tailor-made design, engineering, documentation and technical training receipts under the contracts were treated as fees for technical services because the agreements separately identified engineering charges and the services were rendered in connection with plant supply and erection rather than as part of a construction, assembly, mining or like project undertaken by the recipient itself. The exclusion in Explanation 2 to Section 9(1)(vii) did not apply, as supervisory and engineering services connected with such activities remain within the statutory definition. Technical training abroad for the purchaser's personnel was also held taxable as separate consideration for equipping staff to operate and maintain the plants after commissioning. Both sets of receipts were accordingly taxable as fees for technical services. en-us Mon, 24 Jul 1995 00:00:00 +0530 Mon, 21 Feb 2011 14:18:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66092 Tailor-made design, engineering, documentation and technical training receipts under the contracts were treated as fees for technical services because the agreements separately identified engineering charges and the services were rendered in connection with plant supply and erection rather than as part of a construction, assembly, mining or like project undertaken by the recipient itself. The exclusion in Explanation 2 to Section 9(1)(vii) did not apply, as supervisory and engineering services connected with such activities remain within the statutory definition. Technical training abroad for the purchaser's personnel was also held taxable as separate consideration for equipping staff to operate and maintain the plants after commissioning. Both sets of receipts were accordingly taxable as fees for technical services. Case-Laws Income Tax Mon, 24 Jul 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66092