2012 (9) TMI 913

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....is Revenue appeal against the order of the CIT (A)-8 Mumbai, dated 27.9.2010. The Revenue in its ground is contesting that the CIT(A) erred in deletion of disallowance of Rs..10,42,298/- made under section 40(a)(ia) in respect of VSAT, leaseline and transaction charges without appreciating the fact that these were composite charges for professional and technical services rendered by the Stock Exch....

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.... Revenue is contesting the entire disallowance of Rs. 10,42,298/- whereas as per the order of the CIT (A) the relief was granted only of Rs..2,50,000/-. The Revenue appeal is not maintainable for reason that the relief granted by the CIT (A) being only Rs..2.50 lakhs on the tax effect itself, appeal is not maintainable. 5. Further, there is no bifurcation of the amounts of VSAT, lease line and ....

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....line charges the Revenue did not even contest. Even though the Hon'ble Court held that the transaction charges paid to the Stock Exchange constitute fees for technical services on bonafide belief it was considered that the disallowance cannot be made in that year as the Revenue did not proceed on the footing that assessee is not liable to deduct the tax at source after introduction of the prov....