Services of non-resident agent facilitating fulfillment of export obligations are not in nature of technical services

Brief of the case:

• The Hon’ble Madras High Court in the case of CIT vs. M/s Orient Express held that services of non-resident agent facilitating the completion of export obligations cannot be termed as technical services provided in India because such services are not provided for the purposes of running of the business of the assessee in India.
• Thus, no income can be deemed to accrue or arise in India within the meaning of sec 9(1)(vii) of the Act.

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