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TMI Blog2015 (12) TMI 968X X X X Extracts X X X X X X X X Extracts X X X X ..... ith the foreign entities (agents) and concluded that the services rendered by the ‘agents’ were purely in the nature of advancement of the business of the Assessee which could not be categorized as managerial/technical or consultancy services. Consequently, it was held that the consideration paid by the Assessee to such agents could not be classified as fee for technical services. The Court fin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not arise. - Decided in favour of assessee. - ITA 489/2015 & ITA 491/2015 - - - Dated:- 10-8-2015 - DR. S. MURALIDHAR MR. VIBHU BAKHRU JJ. For the Appellant: Mr. Rohit Madan, Senior Standing counsel with Mr. Akash Vajpai, Advocates. O R D E R 1. In these appeals under Section 260A of the Income Tax Act, 1961 ( Act ) against the order dated 19th December 2014 passed by the Incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... services. Consequently, it was held that the consideration paid by the Assessee to such agents could not be classified as fee for technical services. 3. The Court finds that the view taken by the ITAT on the interpretation of clauses of the agreements in question was a plausible one. It is also consistent with the decision of this Court in DIT v. Pan Alfa Auto Elektrik Ltd. [2014] 272 ITR 117 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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