TMI Blog2023 (12) TMI 652X X X X Extracts X X X X X X X X Extracts X X X X ..... d fee for technical services (FTS)? - tribunal deleted addition - HELD THAT:- Tribunal [ 2022 (9) TMI 1538 - ITAT DELHI] had sustained the order of the CIT(A) as held that the findings of the CIT(A) had not been rebutted. Tribunal further held that the AO had failed to list out the highly technical services that the AEs provided to the petitioner/assessee and that the AO failed to allude to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Nikhil Agarwal, Mr Nishank and Ms Harshita Agrawal, Advs. For the Respondent Through: Mr Zoheb Hossain, Sr Standing Counsel with Mr Sanjeev Menon, Standing Counsel. RAJIV SHAKDHER, J.: (ORAL) 1. The substantive relief sought by the petitioner in the writ petition reads as follows: (a) Issue a writ of CERTIORARIFIED MANDAMUS or any other appropriate writ, order or direction ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sallowance was ordered by the Assessing Officer (AO) under Section 40(a)(i) of the Income-tax Act, 1961 [in short, Act ], while framing the assessment order, under Section 143(3) of the Act, on 27.12.2016. 4. The record shows [and something which is not disputed by the respondent/revenue] that the aforementioned addition, amounting to Rs. 2,06,29,647/-, had been deleted by the Commissioner of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... with the AEs was made available to the petitioner/assessee. Finally, it was also observed that this issue had been decided by the CIT(A) in favour of the petitioner/assessee in matters concerning AYs 2010-11 and 2014-15, decisions that were not challenged before the Tribunal. 6. Mr Zoheb Hossain, learned senior standing counsel, who appears on behalf of the respondent/revenue, says that the a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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