Sum paid to foreign co. for production of 2D and 3D animated films wasn’t fees for technical service

IT/ILT : Where assessee, engaged in production of 2D and 3D animation films, having received orders from various companies for production of animation films, outsourced a part of projects to overseas clients on contract basis, since there was no element of any technical services in production of animation films, provisions of section 9(1)(vii), did not apply to payments made by assessee to foreign sub-contractors