SCB's Payment to Assessee Not "Fees for Technical Services" u/s 9(1)(vii) of Income Tax Act. No Human Intervention.

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....Royalty/fees for technical services u/s. 9 (1) (vi)/9 (1)(vii) - payment made by SCB to assessee company does not fall within the realm of “fees for technical services‟ as contained in Sec. 9(1)(vii), albeit the assessee has only provided a standard facility for data processing without any human intervention - AT....