(i). Llyods Register Industrial Services (India) P. Ltd. v. ACIT

RENAISSANCE SERVICES BV,MUMBAI vs. DCIT (INTERNATIONAL TAX) 4(1) (1), MUMBAI

In the result, appeal filed by assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyalrenaissance Services Bv, C/O Marriott Hotels India Pvt. Ltd. 303A, 304, Fulcrum, B-Wing, Hiranandani Business Park, Sahar Road, Andheri (East), Mumbai-400099 Pan: Aaecr4995E ...... Appellant Vs. Dcit (International Taxation)-4(1)(1), 17Th Floor, Room No. 1712, Air India Building, Nariman Point, Mumbai-400021 ..... Respondent

…d by the assessee from providing training services being in the nature of managerial/leadership training, thus could not have been assessed as FTS in the hands of the assessee, as under: (i). Lloyds Register Industrial Services (India) P. Ltd. vs ACIT (2010) 36 SOT 293 (Mum): The Tribunal observed that the expenses incurred by 13 ITA No. 1526, 1760 & 2360/Mum/2021-Renaissance Services BV the assessee who was engaged in the business of survey of ships, on the training of its employees who would inspect various mechanical and electrical equipments us the ship and ultimately issued a fitness certificate, could no…

DCIT (IT) -4(1) (1), MUMBAI vs. RENAISSANCE SERVICES BV, MUMBAI

1758/Mum/2021 2013-14

…ng training services being in the nature of managerial/leadership training, thus could not have been assessed as FTS in the hands of the assessee, as under: M/s. Renaissance Services BV (i). Llyods Register Industrial Services (India) P. Ltd. vs. ACIT (2010) 36 SOT 293 (Mum): The Tribunal observed that the expenses incurred by the assessee which was engaged in the business of survey of ships, on the training of its employees who would inspect various mechanical and electrical equipments in the ship and ultimately issued a fitness certificate, could not be held as payments made for technical services. The Tribuna…

DCIT (IT) -4 (1) (1) , MUMBAI vs. RENAISSANCE SERVICES BV, MUMBAI

1758/Mum/2021 2013-14

…ng training services being in the nature of managerial/leadership training, thus could not have been assessed as FTS in the hands of the assessee, as under: M/s. Renaissance Services BV (i). Llyods Register Industrial Services (India) P. Ltd. vs. ACIT (2010) 36 SOT 293 (Mum): The Tribunal observed that the expenses incurred by the assessee which was engaged in the business of survey of ships, on the training of its employees who would inspect various mechanical and electrical equipments in the ship and ultimately issued a fitness certificate, could not be held as payments made for technical services. The Tribuna…

RENAISSANCE SERVICES BV,MUMBAI vs. ACIT (INTERNATIONAL TAX) 4(1) (1) , MUMBAI

1758/Mum/2021 2013-14

…ng training services being in the nature of managerial/leadership training, thus could not have been assessed as FTS in the hands of the assessee, as under: M/s. Renaissance Services BV (i). Llyods Register Industrial Services (India) P. Ltd. vs. ACIT (2010) 36 SOT 293 (Mum): The Tribunal observed that the expenses incurred by the assessee which was engaged in the business of survey of ships, on the training of its employees who would inspect various mechanical and electrical equipments in the ship and ultimately issued a fitness certificate, could not be held as payments made for technical services. The Tribuna…

RENAISSANCE SERVICES BV,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, appeal of the assessee for A

…ved by the assessee from providing training services being in the nature of managerial/leadership training, thus could not have been assessed as FTS in the hands of the assessee, as under: (i) Llyods Register Industrial Services (India) P. Ltd. v. ACIT (2010) 36 SOT 293 (Mum): The Tribunal observed that the expenses incurred by the assessee which was engaged in the business of survey of ships, on the training of its employees who would inspect various mechanical and electrical equipments in the ship and ultimately issued a fitness certificate, could not be held as payments made for technical services. The Tribuna…

RENAISSANCE SERVICES BV,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, both the appeal filed by assessee is allowed

Bench: Shri G.S. Pannu, Vice- & Shri Pawan Singh

…IN THE INCOME-TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI G.S. PANNU, VICE-PRESIDENT AND SHRI PAWAN SINGH, JUDICIAL MEMBER ITA No. 764/Mum/2017 (Assessment Year 2012-13) Renaissance Services BV, DDIT (International C/o MMR & Associates LLP, Taxation) -4(1) Vs. BMR House, 36B, Dr. R.K. Room No. 1712, 7th Floor, Air India Building, Shirodkar Marg, Parel, Mumbai-400012 Nariman Point, PAN: AAECR4995E Mumbai-400021 Appellant Respondent Appellant by : Shri Paras Savla with Shri Pratik Poddar (AR) Respondent by : Shri Nishant Samaiya (Sr. DR) Date of Hearing : 15.05.2019 Date of Pronouncement : 09.08.2019 O…

RENAISSANCE SERVICES BV,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

The appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri G.S.Pannu, Am & Shri Ravish Sood, Jm Renaissance Services Bv The Deputy Director Of C/O Bmr & Associates Llp Income-Tax (International बिधम/ Bmr House, 36B Taxation)-2(1), 1St Floor 36B, Dr. R.K Shirodkar Marg, Room No. 120, Scindia Vs. Parel, Mumbai- 400 012 House, Ballard Estate Mumbai- 400 038 स्थामी रेखा सं./ जीआइआय सं./ Pan No. Aaecr4995E (अऩीराथी /Appellant) (प्रत्मथी / Respondent) :

…at as „training services‟ are not technical in nature, hence the consideration received in lieu thereof cannot be brought to tax as FTS, relied on the following judicial pronouncements: (i). Llyods Register Industrial Services (India) P. Ltd. vs. ACIT (2010) 36 SOT 293 (Mum). (ii). Ershisanye Construction Group India (P) Ltd. vs. DCIT (2017) 84 taxmann.com 108 (Kol). (iii). ACIT Vs. PCI Ltd. (2011) 12 taxmann.com 59 (Delhi) (iv). ITO Vs. Veeda Clinic Research P. Ltd. (2011) 13 taxmann.com21 (Bang) (v). Wockhardt Ltd. Vs. ACIT (2011) 10 taxmann.com 208 (Mum). The ld. A.R taking support of the order of the ITAT,…