Remuneration received for providing legal service not amount to ‘fees for technical services’

Linklaters LLP Vs Asst  Vs CIT (IT)-3(1)(2) Mumbai (ITAT Mumbai) ITAT Mumbai held that remuneration received for providing legal services doesn’t amount to ‘fees for technical services’, where the provisions of section 9(1)(vii) of the Act is not applicable. Accordingly, the same is not taxable. Facts- The assessee is a LLP incorporated under the laws of United Kingdom, engaged in providing legal services. The assessee is registered with the Registrar of Companies for England and Wales under the Limited Partnership Act, 2000 of the UK. The assessee provides legal services to its clients...