https://www.taxtmi.com/caselaws?id=221026 Payment to a foreign testing laboratory for automated type testing of circuit breakers was not fees for technical services under section 9(1)(vii) read with Explanation 2. Applying noscitur a sociis, the expression "technical services" was read with the associated human-element concepts of managerial and consultancy services, so mere use of sophisticated machines or a standard testing facility without meaningful human intervention did not qualify. On the facts, the laboratory performed destructive tests through automated equipment and issued reports and certificates, and the authorities did not show that the service depended on human technical skill. The remittance was therefore not chargeable under the provision, and no tax deduction at source was required. en-us Tue, 12 Feb 2013 00:00:00 +0530 Mon, 28 Oct 2013 17:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=221026 Payment to a foreign testing laboratory for automated type testing of circuit breakers was not fees for technical services under section 9(1)(vii) read with Explanation 2. Applying noscitur a sociis, the expression "technical services" was read with the associated human-element concepts of managerial and consultancy services, so mere use of sophisticated machines or a standard testing facility without meaningful human intervention did not qualify. On the facts, the laboratory performed destructive tests through automated equipment and issued reports and certificates, and the authorities did not show that the service depended on human technical skill. The remittance was therefore not chargeable under the provision, and no tax deduction at source was required. Case-Laws Income Tax Tue, 12 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=221026