TMI Blog2015 (10) TMI 486X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 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 such audit party, a certificate to individual clients/applicants are issued. This is after reviewing the report and several stages of audit work which has been carried out. The certificates are issued for specific and certain period. These are neither te ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der 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 once the fees are not falling within above provisions, then, further question and of applying section 44D and Section 115A of the Income Tax Act, 1961 would not arise. - INCOME TAX APPEAL NO.1304 OF 2013 - - - Dated:- 20-4-2015 - S.C. DHARMADHIKARI AND A.K. M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... these clients cases. To enable them to obtain certification so that the products of such clients are certified to meet with the International Quality standards. In the circumstances the Tribunal should not have termed them as not covered by the statutory provision and the fees recovered therefor are thus for technical services. In any event this is not a substantial question of law. 3. The Trib ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re neither technical nor managerial nor consultancy services. There is no advice given but insofar as this activity is concerned, the record indicates that the audit work and certification would not come within the realm of fees for technical services. In the circumstances, there is nothing in the activities which could enable the revenue to bring them within the purview of section 9 (1)(vii) and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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