Services in which human intervention is not required are not covered by scope of section 9(1)(vii)

As regards assessee’s submission that the provisions of section 9(1)(vii) will not come into play in this case because the entire testing process is automated, it is well settled that when no human intervention is involved in any services, such services cannot be treated to be of the nature which can be covered by the scope of section 9(1)(vii). It is also undisputed that question is not of more or less of human involvement. It is, the question of presence of or absence of human involvement. Furthermore testing charges paid by assessee, a manufacturer and exporter of leather goods, to a ...