https://www.taxtmi.com/caselaws?id=466871 The petitioner contends that the decisive legal issue-whether the consideration amounted to fees for technical services under Section 9(1)(vii) Explanation 2 of the Income-tax Act, 1961-was reformulated in the earlier judgment and not substantively addressed; the Court directs recall of the 09.07.2014 disposal for further hearing to determine that characterisation, treating the reformulation as sufficient ground to relist the appeal and decide the substantial question of law as framed on 08.01.2013. en-us Fri, 01 May 2015 00:00:00 +0530 Mon, 23 Feb 2026 19:00:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466871 The petitioner contends that the decisive legal issue-whether the consideration amounted to fees for technical services under Section 9(1)(vii) Explanation 2 of the Income-tax Act, 1961-was reformulated in the earlier judgment and not substantively addressed; the Court directs recall of the 09.07.2014 disposal for further hearing to determine that characterisation, treating the reformulation as sufficient ground to relist the appeal and decide the substantial question of law as framed on 08.01.2013. Case-Laws Income Tax Fri, 01 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466871