( 1 ) THE question for decision raised by these writ petitions is whether the services of managing agents rendered by an Indian Company to a foreign company are "technical services" within the meaning of section 80-0 of the Income-tax Act, 1961 (the Act ). Messrs. J. K. (Bombay) Ltd. , an Indian Company, that is the managing agents, entered into two agreements with two foreign companies, namely, (1) The Raymond Woollen Mills (Kenya) Limited, and (2) Raymond (Mauritius) Limited. As the foreign companies were desirous of setting up Woollen Spinning and Weaving Plants and the managing agents were the managing agents of a woollen mill in India and possessed technical information and expert industrial, A commercial and scientific knowledge, experience and skill with regard to the setting up and working of woollen spinning and weaving plants, the managing agents agreed to act as the managing agents of the foreign companies for certain fixed terms. The managing agents were to be remunerated for their services by payment of 10 per cent of the net profits of the foreign companies. The managing agents were to be responsible for the design, lay-out, engineering and initial