2024 (12) TMI 1779

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.... the Appellant Through: Mr Ruchir Bhatia, SSC, Mr Anant Mann, JSC and Mr Abhishek Anand, Advocate. For the Respondent Through: 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 (hereafter the impugned order) passed by the learned Income Tax Appellate Tribunal (hereaf....

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....held that the receipts were not chargeable as fees for technical services. 3. In the aforesaid context, the Revenue has projected the following questions for consideration of this court:- "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(1)(vii) of the....