2021 (2) TMI 1351

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..... ENCH This assessee's appeal for A.Y. 2014-15 is directed against the Commissioner of Income Tax (Appeals)-10 ['CIT(A)' for short], Hyderabad's order dated 19.04.2018 in case no. 0202/2016-17, involving proceedings u/s 143(3) of the Income Tax Act, 1961 [ 'the Act' for short]. Heard both parties. Case file perused. 2. It transpired at the outset that the assessee's sole substantive grievance ch .....

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..... as redundant. We find no merit in Revenue's foregoing stand. Various judicial precedents hon'ble Bombay high court in CIT vs. Avtar Singh Wadhwan reported in 247 ITR 260 (Bom.) ; DIT vs. Prahlad V Rao 198 taxman 551 (Kar) and Utanka Roy vs. DIT WP no.369/2014 dated 15.12.2016 (Calcutta HC) hold that such an income derived by a non- resident for performing service activities outside India, the accr .....

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