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2018 (7) TMI 2031 - ITAT MUMBAITDS u/s 195 - default u/s 201(1) & 201(1A) - search services rendered by the assessee to its clients based on utilization of data base received by assessee under separate license agreement - PE in India - DTAA with Netherlands - HELD THAT:- As gone through the tribunals order in the case of Spencer Stuart International BV [2018 (6) TMI 359 - ITAT MUMBAI] , wherein the issue for consideration for the year under appeal relates to taxability of search services fee received by assessee from SSIPL under the head fee for technical services. We find that the Tribunal has considered this issue and hence, respectfully following the co-ordinate Bench on this very issue, we confirm the order of CIT(A) deleting the addition. - Decided against revenue
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