2016 (2) TMI 1078

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..... enue since that notice is prospective in nature. It is seen that by the order in Pr. Commissioner of Income Tax-3 v. Fiserv India Pvt. Ltd. (2016 (1) TMI 1276 - DELHI HIGH COURT ), this Court has accepted the above plea of the Assessee. Even otherwise, the decisions referred to by the ITAT in the impugned order on the issue also answer the question in favour of the Assessee and against the Revenue .....

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..... ut by the learned counsel for the Assessee that reliance placed by the Revenue on the Safe Harbour Notification dated 18 th September 2013 will be of no avail to the Revenue since that notice is prospective in nature. It is seen that by the order dated 6th January 2016 in ITA No. 17/2016 (Pr. Commissioner of Income Tax-3 v. Fiserv India Pvt. Ltd.), this Court has accepted the above plea of the As .....

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