Consultancy services which are not of a technical nature cannot be treated as technical services

Brief of the Case

ITAT Ahmedabad held In the case of Shell Global Solutions International BV vs. ITO that as clearly stated in the MoU to the Indo US tax treaty, which stands incorporated in the Indo Dutch tax treaty as well by the virtue of MFN clause, consultancy services which are not of a technical nature cannot be treated as technical services.

Also it is clear that as long as the services rendered by the assessee are managerial or consultancy services in

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