2008 (7) TMI 44

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....sentative (DR), for the appellant. Shri Tushar Jarwal, Advocate, for the Respondent. [Order per. Rakesh Kumar Member (Technical)] - The point of  dispute in this appeal of the Revenue is as to whether during 2001-02 to 2004-05 period, the Respondent, who in terms of an agreement for knowhow transfer and technical collaboration with M/s Matsushita Electric Industries Co. Ltd., Japan (M/s....

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....ngineer', includes rendering of 'technical assistance' in any manner to a client in one or more discipline of engineering. (ii) Whatever amount has been paid by the Respondents to M/s MEI, Japan as royalty is nothing but technical assistance fee. 2.2 Shri Tushar Jarwal, Advocate, the learned counsel for the Respondents, pleaded that the Respondent's agreement with MEI, Japan ....

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....ting engineer's service. 3. We have given careful consideration to the submissions from both the sides. From the agreement of the Respondent with MEI, Japan, it is clear that this is not an agreement for engineering consultancy, but an agreement for giving right to the Respondents to use certain technology, developed and patented by MEI, for manufacture of Dry battery cells in India, for wh....