https://www.taxtmi.com/caselaws?id=215514 Payments to non-resident workshops for repair, refurbishment, assembly, disassembly, inspection and evaluation of goods exported abroad are not fees for technical services because no intellectual or technical element or personnel involvement of the payer is shown; the activities are routine maintenance and repair rather than managerial, consultancy or technical services as defined in the relevant tax explanation. Consequently, such cross-border payments for workshop repairs do not attract characterization as fees for technical/managerial services and are not taxable on that basis in the hands of the payer. en-us Tue, 31 Jul 2012 00:00:00 +0530 Tue, 20 Jan 2026 17:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215514 Payments to non-resident workshops for repair, refurbishment, assembly, disassembly, inspection and evaluation of goods exported abroad are not fees for technical services because no intellectual or technical element or personnel involvement of the payer is shown; the activities are routine maintenance and repair rather than managerial, consultancy or technical services as defined in the relevant tax explanation. Consequently, such cross-border payments for workshop repairs do not attract characterization as fees for technical/managerial services and are not taxable on that basis in the hands of the payer. Case-Laws Income Tax Tue, 31 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215514