2015 (10) TMI 486

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..... es the order passed by the Income Tax Appellate Tribunal, Mumbai dated 6th July, 2012 reversing the orders of the Assessing Officer and the Commissioner. The only argument canvassed before us and based on which all the questions are proposed and projected is that the Tribunal completely misread and misinterpreted section 9(1)(vii) of the Income Tax Act, 1961 and Article 12(4) of the Indo German Do .....

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..... tionally acclaimed, namely, ISO. The certification is of various standards ISO 9001/2, ISO 14001, QS 9000 etc. 4. The nature of work is that the assessee is approached by certain parties for issuance of this standard certificate. The process of evaluation in the form of audit of activities undertaken by the clients is carried out through the audit parties of the assessee. Based on the report of s .....

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..... ds and the service and their nature. Having analysed all this, the Tribunal concluded that the assessee's services are not of the nature falling within statutory provision. In these circumstances, the findings of fact at paragraph 9 and 10.3 of the order under challenge cannot be termed as perverse or vitiated by any error of law apparent on the face of the record. It is fairly conceded that o .....

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