2025 (3) TMI 49

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....learned counsel for the parties. 2. This appeal concerns the assessment year 2008-2009. 3. Mr. Bhate, learned counsel for the Appellant-Revenue, proposes the following substantial question of law which, according to him, arises in this appeal:- "Whether in the facts and in the circumstances of the case and in law, the, Hon'ble ITAT was justified in not upholding the order of the A.O. that tax ....

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....ondent, submitted that there are concurrent findings of fact that the payments made under the agreement with IGSPT did not involve any provision for professional / managerial / technical expertise services to the assessee. He submitted that there are concurrent findings of fact on this issue and such findings are based on the agreement and other material on record. He, therefore, submitted that no....

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.... assessee and IGSPT and the other material on record, such as the details of the call service executives, their qualifications, and the nature of work they discharged. Therefore, the concurrent findings of fact cannot be said to suffer from perversity either because they are based on no evidence or because they are contrary to the weight of the evidence on record. 9. The CIT(Appeals) and ITAT hav....