Mere rendering of service without transfer of technical knowledge is not Fees for Technical Service

CIT Vs Star Rays (Gujarat High Court) Gujarat High Court held that mere rendering of services cannot be roped into Fees for Technical Service (FTS) unless the person utilizing the services is able to make use of the technical knowledge etc. Simple rendering of services is not sufficient to qualify as FTS. Facts- The issue involved in the present matter is that the assessee committed an error in mentioning the name of beneficiary while filling entry in Form 15CA/15CB. It mentioned in the form that the remittance advice issued by the Bank of India is also in the name of GIA Hong Kong Laboratory...