Tribunal held that,inspection and survey of imported and exported cargo and certifying in relation to quality and price .No technical knowledge, experience, skill, know-how or processes made available to recipient of service. Not chargeable to tax in India ( AY.2010-11 2014-15)
Inspectorate International Ltd. v. ACIT (2018) 65 ITR 333/ 171 ITD 630 (Delhi) (Trib)
S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Inspection and survey of imported and exported cargo and certifying in relation to quality and price — No technical knowledge, experience, skill, know-how or processes made available to recipient of service — Not chargeable to tax in India -DTAA- India – UK [ Art.13(4)(c ) ]