2019 (2) TMI 524
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....o, Adv. And Sh. Purushottam Anand, Adv. ORDER PER BEENA A PILLAI, JUDICIAL MEMBER Present Cross appeals have been filed by revenue as well as assessee against order dated 27/02/15 passed by Ld.CIT(A)-3, New Delhi on following grounds of appeal: ITA 2821/Del/15 (Revenue) "1. Whether on the facts and in the circumstances of the case and in law, Ld.CIT(A) has erred in deleting the addition ....
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.... computing tax demand of the Respondent Assessee. 2. That, based on facts and circumstances of the case, the learned CIT(A) and the Assessing Officer ought to have granted TDS credit of Rs. 18,99,261 while computing tax demand of the Respondent Assessee. 3. That the Learned CIT(A) erred in not specifically adjudicating on the issue that no interest u/s 234B of the Act could be levied in fact....
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....t, 1956 and is primarily engaged in providing engineering and technical consultancy services and execution of contracts on a Turnkey basis predominantly in Oil/Gas/Hydro Carbon Sectors. The assessment u/s 143(3) of the Income Tax Act, 1961 (the Act) was finalised at total income of Rs. 7,16,62,27,270/- after making disallowance of Rs. 9750/- u/s 14A of the Act, and disallowance of Rs. 94,91,410/- ....
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....Bench of this Court in CIT vs. Eon Technology (P) Ltd. 2011 (203) taxman 266, where the Court in similar circumstances held that providing such services, in respect of activities abroad, do not constitute fee for technical services and therefore, disallowable u/s 40(a). In view of these circumstances, no substantial question of law arises. The appeal is consequently dismissed." 4. Ld.Sr.DR thoug....