2020 (3) TMI 1248

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.... For the Department : Shri B.Rama Krishna, Sr.DR ORDER PER V. DURGA RAO, JUDICIAL MEMBER By filing this Misc. Application assessee seeks recall of the order passed by this Tribunal in ITA No.541/VIZ/2018 vide order dated 30/04/2019 on the ground that ground Nos. 5 & 6 are not adjudicated. 2. The Revenue has raised the following grounds of appeal:- "1. The order of the Ld. CIT(A)-1, Guntur is....

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....ents made in the nature of 'Fee for technical service' are to be disallowed and Ld.CIT(A) should have confirmed the addition made by the Assessing Officer as the assessee failed to prove that the amount paid to foreign agents was not in the nature of 'Fee for Technical Services'. 5. Ld.CIT(A) erred in not relying on the ratio of the Hon'ble Supreme Court in the case of Rajend....