2025 (9) TMI 1832

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....Decisions)<br>Dated:- 17-9-2025<br>Income Tax Appeal No. 128 of 2024 - -<br>Income Tax<br>HON&#39;BLE MR. JUSTICE S.G. PANDIT AND HON&#39;BLE MR. JUSTICE K. V. ARAVIND For the Appellants : Sri. E.I. Sanmathi, Senior Standing Counsel. For the Respondents : None. ORAL JUDGMENT (PER: HON&#39;BLE MR. JUSTICE S.G. PANDIT) This appeal is filed raising the following common substantial ques....

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....n Explanation 2 to Section 9(1)(vii) of the Act and the Double Taxation Avoidance Agreement as well are fully satisfied in present case? 3. Whether on the facts and in the circumstances of the case, the Tribunal&#39;s order is perverse in nature in ignoring the various clauses of the Agreement which signified that the overseas entity through the employees rendered technical, managerial an....

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....Taxation) vs. Abbey Business Services India (P) Ltd., [(2020) 122 taxmann.com 174] and in the case of Deputy Commissioner of Income Tax (International Taxation) and others vs. M/s. Flipkart Internet Pvt. Ltd., [(2025) SCC OnLine Kar 16629]. The Co-ordinate Benches after considering the clauses and the contentions raised by the appellants-Revenue has held that, such technical services provided by t....