2024 (7) TMI 1797

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....57, Mumbai, dt. 31/05/2023 pertaining to AY 2016-17. 2. The grievance of the revenue reads as under:- "Ground of appeal No. 1 The services provided by the assessee to the Mckinsey group are not general in nature and not available in public domain they are providing specifically to the Mckinsey group and sector specific expert professional which are the used by the recipient in the different decision making from financial to legal issues and are in the nature of consultancy services and treated as fees for technical services under section 9(1)(vii) of the Income Tax Act, 1961. Therefore the Ld. CIT(A) erred in the nature of consultancy services to the borrowed services fees received by the assessee. Ground of ap....

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....r Pricing Study report in Form 3CEB was filed. The assessee is part of McKinsey group of entities, the primary business of which is to render st4rategic consultancy services to their clients, which inter alia includes the analysis of performance, developments, strengths, and weaknesses of their clients, improving their profitability and productivity, and similar other parameters. All these services have been performed outside India and since they have been rendered in the ordinary course of business, the receipts on account of the same amounting to Rs.6,79,39,779 qualified to be a business receipt of the assessee. Since the assessee-company has no PE in India, the incidence of tax does not arise in India. During the course of scrutiny asses....