9911796707
TMI Blog2020 (3) TMI 1438X X X X Extracts X X X X X X X X Extracts X X X X ..... regard, the assessee has placed reliance on the judgment by the Hon'ble Karnataka High Court rendered in the case of Bharat Hotels Ltd (2016) 384 ITR 77(Kar.) as per ground no. 2.2 raised by the assessee in ITA No.490(B)/2019 and similar ground in all remaining appeals. 2.1 On merit, this is the grievance of the asessee that all these appeals relate to the impugned payment made by the assessee during these 7 years towards marketing services and fees for facilitation services and the same cannot be considered as fees for technical services (FTS) or royalty u/s 9(i)(vi) & (vii) of IT Act, 1961 r.w. Article-12 of India-USA-DTAA. 3. Regarding time barring aspect, ld. AR of the assessee has placed reliance on the Tribunal order rendered in the case of Wipro Limited Vs Addl. CIT in ITA No.1215 to 1220(B)/2014 in support of this contention that at least the orders passed by the AO u/s 201(1)( and 201(1A) of the Act for FY: 2010 - 11 relevant to AY: 2011 - 12 are barred by limitation because it was held by the Tribunal in this case as per para-99 of this Tribunal order that period of limitation for initiation of proceedings for resident as well as non-resident u/s 201(1) should be 6 year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reference, we reproduce the same herein below; SYNOPSIS by the learned DR of the revenue 1. Ground 1: General 2. Ground 2: Limitation 2.1. For the year under consideration as the law stood then or even now no period of limitation was is prescribed under section 201 for exercise of power thereunder in context of Non-Residents. Subsection 3 to section 201 was inserted vide Finance Act 2009 with effect from 01/04/2010. The objective of insertion of this section was explained in the memorandum to the Finance Bill 2009 which is reproduced in the order of CIT Appeal at page 28 (page 42 of Assessee's paper book). 2.2. The Memorandum clearly States that no time limits have been prescribed for the order under section 201(1) where the deductee is a nonresident as it may not be administratively possible to recover th tax from the Non Resident. Thus the legislative intent has been amply brought out in the memorandum when it is stated the limitation shall not apply in the case of non residents. Reliance is placed on the following decisions: a) In the case of Uttam Namdeo Mahale wherein Hon'ble Supreme Court held that that if no limitation has been prescribed, then it can be exec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovided by the Non Resident entity to the assessee is not in public domain and is solely made available to assessee for economic benefit to be derived from such information. It is a case of payment for use of information concerning commercial experience and squarely falls within the definition of Royalty as per Article 12(3)(a) of Indo-US DTAA(DTAA and the relevant Article are at Page 123 of Assessee's Paper Book). 3.3. Strong Reliance is placed on the decision of Jurisdictional ITAT in case of TNT Express Worldwide (UK) (Annexure 9). 3.4. The Hon'ble ITAT, on similar facts, held that "it appears to be a composite agreement for providing various services, some of which are purely business commercial practice & contract services and others are in the nature of imparting the knowledge, experience, which concern the commercial or business experience.". The payments were held to be in the nature of Royalty. This order dealt with commentary in OECD Model Tax Convention which is a relevant guide for deciding the nature of payment whether it is Royalty or business income. (Relevant extract at Pg 21 of the Order at page 106 of Department's Paper Book). The relevant extract i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y is made, then there is no application of "Make Available" clause. This clause is required to be satisfied ONLY if the payment is for technical or consultancy services falling within clause (b) of Article 12(4). Hence the arguments of the appellant are not tenable. 6.2. Notwithstanding the above contention, the requirement of "Make Available" is not confined to "technology". As is clear from Article 12(4)(b), it involves making available 'technical knowledge', 'experience', 'skill', 'know how' OR processes. The word "OR" is important. The mail correspondence (provided by assessee during the proceedings) abundantly makes it clear that the experience and skill has been made available, thus satisfying the "Make Available" clause of DTAA. Copies of mail correspondence are at Annexure 6 & 7. Relevant Pages are as follows: Page No Email dated Email From Email To 61 02/12/2016 Todd Brownrout (of Ad2Pro.USA) Kartic, employee of Assessee Company 62 02/12/2016 Todd Brownrout (of Ad2Pro.USA) Kartic, employee of Assessee Company 62 02/12/2016 Badri Narayan(from Assessee's Co ) Kartic, 65 04/01/2017 Todd Brownrout Kartic, 66 07/04/201 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sed) 8.Ground 3.6.3 to 3.6.7 : Not argued by Ld AR on 20/01/2020. 9. Ground 3.7 : Royalty (already discussed) 10.Ground 4: Acceptance by Department in Proceedings u/s 143(3) r.w.s 144A. 10.1. Assessee claims that this issue was already discussed by Corporate AO and the payment was accepted without any disallowance. 10.2. This claim deserves to be rejected for the following reasons: 1) Ld AR filed a 'Note' on Pg 414, claiming to have filed it before that AO. No evidence was furnished as to whether this was actually filed before that AO and whether that AO had made enquiry on this issue. 2) The orders of Corporate AO are dated 24/02/2015 & 27/03/2013 ie much prior to the facts called out during survey on 11/07/2017 by AO in International Taxation. The order passed by the present AO is dt 16/02/2018 after detailed inquiry & based on survey material. 3) The AOs in International Taxation have domain knowledge. 4) If the Corporate AO made an error, there is no reason to perpetuate it. Reliance is placed on the decision of Hon'ble Supreme Court in case of "Distributors Baroda" (155 ITR 120), wherein it was held that "to perpetuate an error is no heroism. To rectify it, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... einafter referred to as the "AMSI") based in California USA. AMSI provides marketing services to AMSPL. The consideration is based on Cost-plus Model. Further, AMSI does not have any establishment or Business connection in INDIA and more importantly does not.own any technology in providing these marketing services. 2.3 A survey was conducted under Section 133A(2A) on 11.07.2017 by the Learned Deputy Commissioner of Income Tax (IT), Circle 1(1), Bengaluru [Assessing Officer] for the purpose of verifying the deduction of tax at source and accordingly verification was carried out in the business premises of Appellant. 2.4 During the survey the Learned Assessing Officer sought details in respect of foreign remittances made by the Assessee to Ad2Pro Media Solutions, Inc, USA (AMSI, USA), [a wholly owned subsidiary company of Appellant]. The Learned Assessing Officer issued detailed questionnaire seeking the information on the nature of services rendered by AMSI, USA to the Appellant. In response to the same the authorized representative of the Appellant appeared from time to time and produced the details called for. 2.5 Common order under Section 201 & 201(1A) of the Act dated 16-02- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eedings for resident as well as non-resident u/s 201 should be 6 years from the end of the financial year. Further the payer is required to maintain books of account and deduct TDS for both resident as well as non-resident. No Separate treatment had been envisaged under the Act, for the payer paying to a non-resident. " [Emphasis Supplied] 3.2 Wherefore, in view of the above submissions, since the order under Section 201 & 201(1A) of the Act for the financial year 2010-11 is passed after a period of 7 years, it is prayed for appropriate relief holding that the order u/s Sections 201 & 201(1A) of the Act for the assessment year 2011-12 are barred by limitation. 3.3 The Appellant further submits that with regard to Assessment Years 2012-13, 2013-14 & 2014-15, the orders passed u/s 201 & 201 (1A) are also beyond limitation in terms of provision contained in sub section (3) of Section 201, as it stood for the relevant assessment years, prior to the amendment, which came into effect from 1/10/2014. 4. SUBMISSIONS ON THE MARKET FEE PAID TO US SUBSIDIARY 4.1 The total remittance made by the Appellant to AMSI, USA in respect of AY's 2011-2012 to 2017-18 is Rs.64,60,18,978/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not in possession of the Appellant. It is further submitted that the AMSI does not give any information to the Appellant about the method, manner and/or source as to how it obtains the commercial information for the appellant but only provides end-use information to the Appellant. In other words, AMSI does not 'make-available' to the Appellant the know-how, technology and methodology used in rendering the aforementioned services to the Appellant. It is further submitted that AMSI only procures clients to the Appellant who are located outside India and none of the clients or information provided by AMSI pertains to India. 4.4 The AO as well the CIT(A) have, without understanding the actual transaction which has taken place & without analysing the provisions of the Act and the DTAA, and without application of mind, taken a view that the payments are subject to with-holding of tax under the provisions of Section 195 of the Act, 4.5 The Appellant wishes to re-produce the provisions of Section 195 of the Act for ready reference: "Other SUMS. 195. (1) Any person responsible fir paying to a non-resident, not being a company. or to a foreign company, any interest (not being ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... emed to have been made before that date if the agreement is made in accordance with proposals approved by the Central Government before that date. Explanation 2.- For the purposes of this clause, "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, milling or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head "Salaries". [Emphasis Supplied] 4.9 As per the definition, technical services mean services which managerial or technical services rendered. It is a settled position of law that, every time any transaction is sought to be taxed in the case of a non-resident, the relevant provisions of the DTAA has to be referred to and the provisions of the DTAA shall prevail over the provisions of the Income-tax Act, 1961. In this regard, reliance is placed on the decision of the Hon'ble Apex Court in the case of Union of India and Another Vs. Azadi BachaoAndola ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n is obtained. I fence by virtue of the information made available to him, the payer will have requisite to obtain the said or similar information by himself, without availing the services of the service provider. In the instant case, as already submitted, AMSI does not 'makeavailable' to the Appellant the know-how, technology and methodology used in rendering the aforementioned services to the Appellant. It is further submitted that AMSI only procures clients to the Appellant who are located outside India and none of the clients or information provided by AMSI pertains to India. 4.12 Hence, the services provided by AMSI which is categorized by the Appellant as Marketing Tee are not covered by the definition of 'Fees for included services' under the India-USA DTAA and consequentially the Appellant is not obligated to with-hold tax at source under the provisions of Section 195 of the Act. 4.13 It is further submitted that the expression 'consultancy' means advisory services and the same does not involve instances where the non-resident is acting as a link between the resident and another party, facilitating the transaction between them, or where the nonre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me.lt is submitted that under Para 16 of the Agreement entered into between the Appellant and AMSI, USA, the parties have clearly agreed that the services rendered by AMSI. USA do not include any services like training, knowledge transfer, transfer of technology, research and development. Even the Learned Assessing Officer does not dispute the same. 4.18 The Appellant further submits that in the India-US DTAA, there are provisions for `Memorandum for Understandings' which describes in some detail the category of services defined in paragraph 4 of Article 12 (Royalties and Fees for Included Services). It also provides examples of services intended to be covered within the definition of included services and those intended to be excluded, either because they do not satisfy the tests of paragraph 4, or because, notwithstanding the fact that they meet the tests of paragraph 4, they are dealt with under paragraph 5. The DTAA clarifies the understanding of the terms `Technical Services and Consultancy Services' in the following manner: "Article 12 includes only, certain technical and consultancy services. But technical services, we mean in this context services requiring exper ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ider also makes available the technology which they used in rendering services, then it falls within the definition of "fees for technical services" as contained in DTAA. However, if technology is not made available along with technical services what is rendered is only technical services and the technical knowledge is withheld, then, such a technical service would not fall within the definition of "technical services" in DTAA and the same is not liable to tax. [Emphasis Supplied] "A plain reading of 12(4) of DTAA makes it clear that only such technical and consultancy service are covered which is either (a) are ancillary and subsidiary to the application or enjoyment of the right. property or information referred to in article 12(3) or (b) 'make available' technical knowledge, experience, skill, know-how etc. We find that rendering of technical service cannot be equated with making available the technical service. Whereas for attracting sec. 9(1)(vii) 'rendering' of technical, managerial or consultancy services by itself is sufficient, the tax treaty between India and USA goes further and requires that rendering of services should fiwther result to 'make av ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome from any source outside India, then, in that situation, such fees would not be deemed to accrue or arise in India. The said exception has two limbs, first is the case of business or profession carried on by Appellant outside India and second is making or earning any income from any source outside India. It is submitted that, without prejudice to the fact that the consideration paid falls under the Exception under the first limb provided under Section 9(1)(vii)(b), it is submitted that if the services were utilized for earning income from source outside India, although the business as such is carried on in India, the second limb would become applicable. As per the second limb of clause (b) of section 9(1)(vii), fee paid in making or earning any income from any source outside India would not be deemed to accrue or arise in India and accordingly, not taxable. 4.24 Reliance is placed on the following decisions namely: (i) Kunwar TrivikramNarain Singh v. State of Uttar Pradesh (1965) 57 ITR 29 (SC); (ii) Lufthansa Cargo India (P) Ltd. v. DCIT (2004) 91 ITD 133 (Delhi); (iii) IBM World Trade Corpn. v. DDIT [2012] 20 taxmann.com 728 (Bangalore - Trib.); (iv) Infosys Technolog ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er submitted that, the information provided by the Non-resident entity to the Appellant is not in public domain and is solely made available to the Appellant for the economic benefits of the Appellant and such an activity falls within the definition of royalty as per the provisions of Article 12(3)(a) of the India-US STAA. The Appellant makes the following submissions de-hors and reserving its right to contest that the payments are neither royalty nor Fees for included services and consequentially not liable for with-holding of taxes. 5.2 Prima facie, it is submitted that the assessing officer, while treating the Appellant as `Assessee in Default' as per the provisions of Section 201 & 201(1A) of the Act, has treated the payments made to the US company as Fees for Technical Services (Fees for Included Services as per DTAA) & accordingly invoked the provisions applicable to the same. He has not treated or even considered the payments to be Royalty. The learned CIT(A) in his order u/s 251 has erred in stating that that one of the limbs of marketing services is lead generation, the Market Team generates customer leads by subscribing to customer database, Market Research and analy ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... database. AMSI, USA may, if necessary, use the above for identifying the prospective customers. These leads are evaluated, and good leads are taken forward though e-mails, phone calls and in case client is interested, business meetings would be set up. The Appellant did not have any access to the database, or the online research subscribed by AMSI, USA. There is no interaction between the employees of the Appellant and the employees of database developer. The entire arrangement is between AMSI, USA and the database vendor and the appellant is completely out of picture. 5.7 It is further submitted that no part of payment by the appellant to AMSI, USA is towards subscribing to (a) customer database, (b) market research and (c) analysis and online research data. In fact, AMSI, USA does not itself own any such database or online research data. What the appellant pays to AMSI, USA is towards rendering of certain marketing services. The payment is not made for transfer of all or any rights [including grant of license] of any IPRs listed in Explanation 2 to Section 9(1)(vi). 5.8 It is submitted that the marketing services provided by AMSI USA do not consist of transfer of all or any rig ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rocess referred above which is rendered in line with the decision of the jurisdictional High Court in the case of CIT vs. De Beers India Minerals Pvt. Ltd. [2012] 21 taxmann.com 214 (Kar) wherein the Hon'ble jurisdictional High Court has held that to "make available" technical knowledge, mere provision of service is not enough; the payer must be enabled to perform the service himself The Appellant submits the same is not the case in the instant case as the Appellant is unable to perform the actions of AMSI and further AMSI does not make available to the Appellant the methodology adopted in rendering its services. 6.3 Reliance is also placed on the decision of the jurisdictional High Court in the case of DIT v. Sun Microsystems India (P.) Ltd. [2014] 369 ITR 63 (Kar) wherein the Hon'ble Court has held that: 6.4 The Appellant further submits that, the test of 'make available' must fulfil the following conditions namely: Mere rendering of specific technical services is not sufficient to attract definition of 'fees for technical services'. The services rendered should make available technical knowledge, experience, skill, know-how, etc. (ii) To fit into &# ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt to AMSI is not a technical fee within the meaning of Section 9(1)(vii) read with Article 12 of the DTAA and that the marketing fee is only paid for business facilitation and not for imparting any technical know-how or technical information. (III) AMSI does not 'make available' any technology or methodology or know how to the Appellant as envisaged in Article 12 of the India-US DTAA and the Appellant is not liable to with-hold tax at source on the marketing Fees under the provisions of Section 195 of the Act. (IV) The payment of marketing fee is not in the nature of royalty or composite transaction and the learned CIT(A) is not justified in holding so in his appellate order thereby violating the provisions of Section 251 of the Act and further violating the principles of natural justice. (V) Without prejudice, hold that the Marketing Fee paid by the Appellant to AMSI falls within the exception provided under Section 9(1)(vii)(b) of the Act and consequentially not liable to TDS under Section 195 of the Act. (VI) Grant such other relief that this Hon'ble Bench may deem fit on the facts and circumstances of the case. For the above submissions and the submissions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 47/Kol/2016. This contention was also raised that sec.9(1)(vii) of the Act provides an exception to the general source rule by providing that were the services rendered by the nonresident service provider are utilized by the resident payer for purpose of earning income from any source outside India, then in that situation, such fees would not be deemed to accrue or arise in India. In support of this contention, reliance was also placed on the following judicial pronouncements; i. Kunwar Trivikram Narain Singh v State of Uttar Pradesh (965) 57 ITR 29(SC). ii. Lufthansa Cargo India (P)Ltd v DCIT (2004) 91 ITD 133 (Del.) iii. IBM World Trade Corpn. V DDIT (2012) 20 taxmann.com 728(Bangalore- Trib.) iv. Infosys Technologies Ltd in re (2012) 210 Taxman 295(AAR). 6.1 Regarding this aspect that the payment in question is royalty, it is submitted by ld.AR of the assessee that CIT(A) could not have discovered a new source of income in exercise of his powers u/s 251. It is also submitted that he CIT(A) has never given a notice u/s 251 of the Act giving opportunity to the assessee to show cause as to why the same should not be treated as royalty. It is submitted that for this reason ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -6.2 involves 'make available technical knowledge, experience, skill, know-how or process'. She submitted that various mail correspondences are provided by the assessee during the proceedings and the same abundantly makes it clear that experience and skill had been made available thus, satisfying make available clause of DTAA and she had referred to 7-e-mails during 01-12-2016 to 04-01-2017 being e-mail from Todd Brownrout of Ad2pro Media Solutions, USA to Kartic employee of the assessee company and Mr. Badrinarayanan. She also submitted that in the course of hearing, it was submitted by the ld. AR of the assessee that Todd Brownrout is also a Director of the assessee company and in reply to this, this is the contention raised by the ld. DR of the revenue that these facts supports the case of the revenue and further goes to prove that the skill and experience are made available to the assessee on regular basis. 7.2 Regarding various judgments of which reliance has been placed by the ld. AR of the assessee, it is submitted by ld. DR of the revenue that these judgments are not applicable in the facts of the present case. 8. We have considered rival submissions. First of all, we dea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd the assessee. One of the services being rendered by US-AE is regarding collections of outstanding money on invoices from customers. 8.1 As per the above details about the nature of services received by the assessee from its US-AE, it comes out that the US-AE provides services regarding finding of customers for the assessee company to whom the assessee can render various services. 9. In the above paras we have noted the facts of the case and the nature of services being received by the assessee for various payments made by the assessee without TDS. At this juncture, we feel it proper to re-produce the provisions of Article-12(4) of India-US-DTAA. Some portion of this article is already re-produced by us above, while reproducing the synopsis and written submissions filed by the learned AR of the assessee, but even at the cost of repetition, we re-produce the complete Article 12 of DTAA between India & USA herein below also for ready reference; "ARTICLE 12 Royalties and Fees for Included Services 1. Royalties and fees for included services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, suc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Article, "fees for included services" means payments of any kind to any person in consideration for the rendering of any technical or consultancy services (including through the provision of services of technical or other personnel) if such services: (a) are ancillary and subsidiary to the application or enjoyment of the right, property or information for which a payment described in paragraph 3 is received; or (b) make available technical knowledge, experience, skill, know-how, or processes, or consist of the development and transfer of a technical plan or technical design. 5. Notwithstanding paragraph 4, "fees for included services" does not include amounts paid: (a) for services that are ancillary and subsidiary, as well as inextricably and essentially linked, to the sale of property other than a sale described in paragraph 3(a); (b) for services that are ancillary and subsidiary to the rental of ships, aircraft, containers or other equipment used in connection with the operation of ships or aircraft in international traffic; (c) for teaching in or by educational institutions; (d) for services for the personal use of the individual or individuals making the payment; or (e) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of the Convention. A" 10. As per Article-12(3) as reproduced above, the term 'royalty' has been defined by saying that it includes various things but as per revenue and as per synopsis filed by ld. DR of the revenue, the case of the revenue is this that it is payment for use of information concerning commercial experience and this is the only contention that the payment in question is Royalty because as per the revenue, this payment is for information concerning commercial experience. In this regard, ld. DR of the revenue placed reliance on a Tribunal order rendered in the case of TNT Express Worldwide (UK)(supra). In para13 of this Tribunal order, it is noted by the Tribunal that the AO has given this finding by holding that the asssessee supplied information to TNT India which has been used by TNT India for his own account. The AO further noted in that case that commercial information has been provided by assessee to TNT Express India arises from previous experience which definitely ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rding this aspect that the payment in question is payment for Commercial Experience provided by US AE of the assessee company to the assessee company and therefore, the payment in question is royalty, she has placed reliance on various e-mails between Todd Brownrout of US-AE of the assessee company and Mr.Kartic and Mr. Badrinarayanan, employees of the assessee company. In this regard, this was the submissions of theld.AR of the assessee that Mr.Todd Brownrout is also a Director of the assessee company and therefore, these e-mails from him cannot be considered as e-mail from US-AE. Copy of these e-mails are available on pages 61-73 of the paper book filed by the ld. DR of the revenue. On page-60 of the paper book filed by the ld. DR of the revenue is e-mail from Mr.Kartic Srinivasan to Mr.Todd Brownrout with a copy to Mr.Badrinarayanan on 02-12-2016 and the subject of this e-mail is 'final documents' In this e-mail, it is mainly stated by Mr.Kartic that he along with Mr.Badrinarayanan can clean up the language and there are some other clauses of the proposed agreement and on page-61 of the paper book is the reply from Mr.Todd Brownrout to Mr.Kartic and this e-mail is dated 02-12-20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... As per this e-mail also, no information was provided by Mr. Colin Wheeler regarding commercial experience etc. 13. The next and last e-mail referred to by the ld. DR of the revenue is available on page-73 of the paper book filed by the ld. DR of the revenue and this e-mail is dated Dec.6, 2017 from Mr.Todd Brownrout to Mr.Kartic and Mr.Badrinarayanan. As per this e-mail it is stated that next Tuesday evening and Wednesday they will be host Chris Sahola and Mr.Colin Wheeler of Ciesco Advisors in Chennai. This is regarding support of Ciesco efforts to secure outside investment in 2Adpro. As per this e-mail also, no information was provided regarding commercial experience etc. 13.1 With the above discussions, we have seen that as per these e-mails, no information concerning the commercial experience was provided by Mr.Todd Brownrout or Mr.Colin Wheeler. Hence, these arguments of the ld. DR of the revenue does not support the case of the revenue. 14. Now we deal with the second aspect i.e. fees for included services. Any services to be considered as included service, it is essential that the services provider makes available experience, skill, know-how or process or transfer of ass ..... X X X X Extracts X X X X X X X X Extracts X X X X
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