order procurement services cannot be treated as royalty and fees for technical services

Pure Software Pvt. Ltd. Vs ITO (ITAT Delhi) t is pertinent to note here that in case of the assessee company, two non-resident foreign companies, one by the name of J2S INC, USA and another by the name of NAVOS, Belgium were appointed to locate foreign buyers to whom the assessee company could sale its services. Thus, both the foreign companies rendered order procurement services outside India which is their business activity. Invoices received from the parties also show that services rendered by them were sales procurement services and not fees for technical services or royalties. The content...