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The Tribunal in [2022] 99 ITR (Trib) 607 (ITAT[Bang])  held that training expenses remain out of the purview of definition of “fee for technical services” hence no taxes are deductible on such payments. In this case the assesseemade payment to the non-resident for training for developing soft skills/leadership skills. The assessee in this case has been in service business running a BPO unit and such training inputs is not something that it provides further on to the customers. 


The bench in the context of assessee’s BPO business  held that the fee for the provision of a service will not be a technical fee, unless that special skill or knowledge is required when any advice or service is provided to the customers. 

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