Explanation 2 to Section 9(1)(vii) defines “Fees for Technical Services” as
“Fees for technical services means any consideration (including any lump sum consideration) for the rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head Salaries”
19 October 2010
The explanation to section 9 (1) (vii) excludes certain types of services from the ambit of technical services which are construction, asssmebly or mining etc. In your query the manpower supply is not covered under 194J. 194C squerly applies.
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