"Technical Services" in Section 194J Needs Human Element; Interconnection Services Excluded Under Income Tax Act.

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....FTS - TDS - the expression ‘technical services’ takes colour from the expressions ‘managerial services’ and ‘consultancy services’ which necessarily involve a human element or, what is now a days fashionably called, human interface. - the services rendered qua interconnection/port access do not involve any human interface and, therefore, the same cannot be regarded as ‘technical services’ as contemplated under section 194J of the said Act. - AT....