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2010 (2) TMI 1259

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....he Revenue is against the order of the CIT(A) IV, Mumbai dated 27.01.2009. 2. Ground Nos. 1 to 6 of this appeal pertain to disallowance of Rs. 1,08,833/- of V-SAT charges and Rs. 5,13,287/- of Transaction charges under section 40(a)(ia). The A.O. has discussed this issue vide para 3.1 to 3.9 and held that V-SAT and Transaction charges paid to Stock Exchange are for technical services and theref....

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....fees paid by the members to the Stock Exchange is not for any technical services rendered, so the TDS is not deductible on the same. Accordingly he directed the A.O. to allow the above amounts. 3. The learned D.R. relied on the order of the A.O. whereas the learned counsel on the CIT(A)'s order. Further it was submitted that with reference to the payment made by the members to its Stock Exchang....

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....e infrastructure provided by the Stock Exchange. The CIT(A) has correctly came to the conclusion that these charges are not fees for technical services. Accordingly, respectfully following the Coordinate Bench decisions relied upon (supra) the order of the CIT(A) is confirmed and the grounds are rejected. 5. Ground No. 7 pertains to the issue of set off of brought forwards loss against the brok....