Payment made to NR deputing technicians to render technical services is Fees for Technical Services if the NR is accountable for services

HIGH COURT OF BOMBAY Zuari Agro Chemicals Ltd. Versus Commissioner of Income-tax, Central-I, Bombay It Reference No. 8 of 1993 September 14, 2012 JUDGMENT S.J. Vazifdar, J.   This Income Tax Reference arises out of RA Nos.1052 and 1053/Bom/1991 which, in turn, arise out of ITA Nos.5033 and 5034/B/1986, which were disposed of by the order of the Income Tax Appellate Tribunal dated 9th January, 1991, and pertain to assessment years 1981-82 and 1982-83. 2.(A) The Tribunal has referred the following questions for the opinion of this Court, at the instance of the assessee under se...