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TMI Blog2021 (9) TMI 1431X X X X Extracts X X X X X X X X Extracts X X X X ..... hopra, Adv. For the Revenue : Sh. Bhuvnesh Kulshrestha, CIT DR. ORDER Per Bench : The present appeals have been filed by the assessee against the orders of ld. CIT(A)-42, New Delhi dated 22.10.2018 and the appeal o f the revenue against the order o f ld. CIT(A)- 42, New Delhi dated 22.10 .2018. 2. The appeal of the assessee for the A.Ys. 2013-14 & 2015-16 is against upholding the action of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the appellant has no place of disposal in India in the office of BTIN from where the appellant could have conducted its business in India.............. 44. Considering the facts in totality, and also the fact that the TPO has examined the international transactions and has accepted the same to be at ALP, we do not find any merit the additions made by the DRP. We accordingly, direct the Assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onsidered opinion, the technical or consultancy services rendered should be aimed at and result in transmitting technical knowledge, etc., so that the payer of the service could derive an enduring benefit and utilize the knowledge or know-how on his own in future without the aid of the service provider. The technical knowledge or skills of the provider should be imparted to and absorbed by the rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate Limited 346 ITR 467. 26. In consideration of totality of facts, we are of the opinion that the intermediary services rendered by the appellant do not make available any technical knowledge, skill etc to BTIN and BTIN is not a equipped to apply technology contained in services rendered by the appellant. Therefore, the intermediary services provided by the appellant to BTIN do not tantamount ..... X X X X Extracts X X X X X X X X Extracts X X X X
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