TMI Blog2014 (3) TMI 1028X X X X Extracts X X X X X X X X Extracts X X X X ..... d learned counsel for the appellant. 2 We have perused the orders passed by the Income Tax Appellate Tribunal dated 24th August, 2011 and prior thereto of the Assistant Commissioner, Income Tax (Appeals). 3 The revenue approached the Tribunal against the order of the Commissioner of Income Tax (Appeals) by urging that the said Commissioner has erred in deleting the disallowance made by the Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ces were not rendered in India. In para 6 of the order passed by the Tribunal, it has referred to the appointment order and also the entire record. The nature of the services rendered have also been considered. It is in these circumstances that there was no conclusion that the matter does not fall within the purview of the Explanation 2 and as urged before us. These are matters fully covered by th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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