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TMI Blog2019 (2) TMI 1963X X X X Extracts X X X X X X X X Extracts X X X X ..... Sr. DR. ORDER PER PRASHANT MAHARISHI, A. M. 1. In ITA number 2245/Del/2018 filed for assessment year 2015-16 the assessee has requested for early hearing in appeal filed on 02/04/2018. The assessee submits that the issue involved in the present appeal is whether the receipt not attributable to permanent establishment of the appellant can be taxed as fees for technical services under article ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lier year. In view of this we grant early hearing of the impugned appeal. Accordingly the application of the assessee is allowed. 4. Further both the parties submitted that the issue is squarely covered against the assessee in assessee‟s own case by the decision of the coordinate bench for earlier years and therefore the same is required to be followed in the present appeal also. Therefore ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of the Indian Premier league in September 2007. The assessee entered into an initial contract and subsequent separate service agreement for the services to be provided to the board of control for Cricket in India in relation to IPL. For the purpose of provision of the services it deputed some of its employees for undertaking the on ground implementation and elated supervision activities in Ind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... covered against the assessee by the decision of the coordinate bench in assessee‟s own case for assessment year 2010 - 11 dated 4/10/2016 as well as for assessment year 2011 - 12 to 2014 - 15 dated 8/5/2018. 7. We have carefully considered the rival contentions and find that the above issue is squarely covered against the assessee by the decision of the coordinate bench for earlier years in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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