2018 (1) TMI 739

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....l Chaudhary, Sr. Standing Counsel. For the Respondent : Ms. Ananya Kapoor, Advocate. ORDER The Revenue's grievance in this appeal under 260A of the Income Tax Act, 1961 is that the Income Tax Appellate Tribunal (ITAT) erred with respect to findings on certain disallowances directed by the Assessing Officer (AO). Various issues were urged by the assessee aggrieved by the AO's order for ....

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.... not Fee for Technical Services (FTS) under Explanation 7 to Section 9(2), similar treatment would arise. As far as this is concerned, the Court notices that the ITAT relied upon the interpretation given to similar provisions of various DTAAs in Cushman & Wakefield Pte. Ltd. in Re. 305 ITR 208; Dieter Eberhard Gustav v. CIT 235 ITR 698 etc. and held that since these were not in the nature of FTS, ....