2024 (12) TMI 1598

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.... Sr. Standing Counsel, Mr. Anant Mann, Jr. standing Counsel and Mr. Abhishek Anand, Advocate. For the Respondent : Mr. Vishal Kalra, Advocate. ORDER 1. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 (hereafter the Act) impugning an order 17.05.2024 passed by the Ld. Income Tax Appellate Tribunal (hereafter the ITAT). 2. It is material to note th....

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....nical services. 3. In the aforesaid context, the Revenue has projected the following questions for consideration of this Court:- "2.1 Whether Ld. ITAT has erred in law by holding that the payments received on account of subscription fees does not constitute Fee for Technical Services under Explanation to section 9(l)(vii) of the Act or under sub Article (4) of the Article 12 of the Ind....