https://www.taxtmi.com/caselaws?id=251680 Delhi HC held that commission paid to non-resident for procuring export orders does not constitute fee for technical services under section 9(i)(vii). The court determined that arranging export sales and payment recovery cannot be regarded as consultancy services since the non-resident provided no consultation or advice to the assessee. The non-resident's skill and expertise in automobile marketing were utilized for their own benefit to secure commission, lacking any element of consultation or advice. Technical, managerial, and consultancy services require special skills for provision of advice or management functions, which were not satisfied here. Decision favored assessee against revenue. en-us Thu, 18 Sep 2014 00:00:00 +0530 Mon, 13 Jul 2026 14:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=251680 Delhi HC held that commission paid to non-resident for procuring export orders does not constitute fee for technical services under section 9(i)(vii). The court determined that arranging export sales and payment recovery cannot be regarded as consultancy services since the non-resident provided no consultation or advice to the assessee. The non-resident's skill and expertise in automobile marketing were utilized for their own benefit to secure commission, lacking any element of consultation or advice. Technical, managerial, and consultancy services require special skills for provision of advice or management functions, which were not satisfied here. Decision favored assessee against revenue. Case-Laws Income Tax Thu, 18 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=251680