2017 (8) TMI 294

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..... es to its customers. The preamble of the agreement between the assessee and M/s. Valuefirst Messaging Pvt. Ltd. itself describes that M/s. Valuefirst Messaging Pvt. Ltd. is a company engaged in providing mobile messaging solutions to carry data over mobile network using its mobility platform. There is no technical or professional services, which can be said to have been offered by M/s. Valuefi .....

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..... ed Counsel for the appellant submits that the Tribunal was not justified in law to hold that the provisions of Section 194J is not applicable in respect of the payments made to M/s. Valuefirst Messaging Pvt. Ltd. for providing SMS services as well as technical support services, more particularly, when the service agreement between the assessee and M/s. Valuefirst Messaging Pvt. Ltd. provided for i .....

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..... d in providing mobile messaging solutions to carry data over mobile network using its mobility platform. There is no technical or professional services, which can be said to have been offered by M/s. Valuefirst Messaging Pvt. Ltd. The judgment of the Apex Court in a case of Director of Income Tax (International Taxation) V/s. A.P. Moller Maersk A/S reported in (2017) 392 ITR 186 and another judgme .....

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