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“Section 9(1)(vii)”

Section References (mined)Section 9Section 9(1)(vii)933 judgments

The decision most relied on for Section 9(1)(vii) is Engineering Analysis Centre of Excellence (P) Ltd. v. CIT (432 ITR 471), cited in 914 judgments on BharatTax.

Leading authorities on Section 9(1)(vii)

Engineering Analysis Centre of Excellence (P) Ltd. v. CIT
432 ITR 471 · 2021 · Supreme Court
914
citing judgments

Payments for the supply or use of computer software, where there is no transfer of copyright but only a right to use the copyrighted product, are generally considered business profits and not 'royalty' or 'fees for technical services' under the Income Tax Act, 1961 or relevant DTAAs. This principle also applies to transponder fees, which are not taxable as royalty.

CIT v. Samsung Electronics Ltd.
345 ITR 494 · 2012 · High Court
461
citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

Ishikawajima Harima Heavy Industries Ltd. v. DIT
288 ITR 408 · 2007 · Supreme Court
394
citing judgments

Income from offshore supply of goods and services is not taxable in India if the entire transaction, including transfer of ownership and payments, occurs outside India.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

DIT v. New Skies Satellite BV
382 ITR 114 · 2016 · High Court
325
citing judgments

An amendment to the Income Tax Act, such as the Finance Act, 2012 amendment to Section 9(1)(vi) defining royalty, does not automatically override or alter the definition of 'royalty' as provided in a Double Taxation Avoidance Agreement (DTAA) unless the DTAA itself is bilaterally amended. The definition of royalty in a DTAA remains unaffected by unilateral changes to domestic law.

DIT v. Nokia Networks OY
358 ITR 259 · 2013 · High Court
276
citing judgments

Payments for the supply of software along with telecom equipment are not in the nature of royalty if they are for the use of a copyrighted article, not the copyright itself. Such payments are not taxable in India in the absence of a Permanent Establishment (PE).

CIT v. Toshoku Ltd.
125 ITR 525 · 1980 · Supreme Court
270
citing judgments

A non-resident commission agent is not chargeable to tax in India on commission income if no business operations are carried out in India. Consequently, no TDS is required under Section 195 on such payments.

DIT v. Infrasoft Ltd.
39 Taxmann.com 88 · 2013 · High Court
269
citing judgments

Payments for the use of copyrighted software, without the transfer of any rights in the underlying copyright itself, do not constitute 'royalty' under the Income-tax Act or tax treaties. Such payments are often treated as business income, taxable only if a permanent establishment exists.

Judgments citing Section 9(1)(vii)

Gulf Piping Company Wll, Abu Dhabi vs. Dy Commissioner of Income Tax (International Taxation), Dehradun

ITA 83/DDN/2025[2022-23]Status: DisposedITAT Dehradun14 Jan 2026AY 2022-23

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 9(1)(vii)

which have been held as taxable in India since attributable to a source in India under the head fee for technical services in section 9(1)(vii) of the Act. 5. The Revenue vehemently argues in this factual backdrop that although there is double tax avoidance between India ... residual clause i.e. Article 22 of DTAA. Thus, the income received by the assessee was held to be taxable in India under sections 9(1)(vii) and 115(a)(iii) at 40 per cent of gross amount. On appeal, the Commissioner (Appeals) held part amount to be taxable as royalty

Gulf Piping Company Wll, United Arab Emirates vs. Dy Commissioner of Income Tax (International Taxation), Dehradun

ITA 81/DDN/2024[2020-21]Status: DisposedITAT Dehradun14 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 9(1)(vii)

which have been held as taxable in India since attributable to a source in India under the head fee for technical services in section 9(1)(vii) of the Act. 5. The Revenue vehemently argues in this factual backdrop that although there is double tax avoidance between India ... residual clause i.e. Article 22 of DTAA. Thus, the income received by the assessee was held to be taxable in India under sections 9(1)(vii) and 115(a)(iii) at 40 per cent of gross amount. On appeal, the Commissioner (Appeals) held part amount to be taxable as royalty

Gulf Piping Company Wll, United Arab Emirates vs. Dy Commissioner of Income Tax (International Taxation), Dehradun

ITA 71/DDN/2024[2021-22]Status: DisposedITAT Dehradun14 Jan 2026AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Nabin Ballodia, CA &For Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 9(1)(vii)

which have been held as taxable in India since attributable to a source in India under the head fee for technical services in section 9(1)(vii) of the Act. 5. The Revenue vehemently argues in this factual backdrop that although there is double tax avoidance between India ... residual clause i.e. Article 22 of DTAA. Thus, the income received by the assessee was held to be taxable in India under sections 9(1)(vii) and 115(a)(iii) at 40 per cent of gross amount. On appeal, the Commissioner (Appeals) held part amount to be taxable as royalty

DCIT, Dehradun vs. Intecsea Asia Pacific Sdn Bhd, Hyderabad

The appeal of the assessee is allowed

ITA 153/DDN/2025[2018-19]Status: DisposedITAT Dehradun13 Jan 2026AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 152/Ddn/2025 : Asstt. Year: 2016-17 Ita No. 153/Ddn/2025 : Asstt. Year: 2018-19 Dcit, Vs Intecsea Asia Pacific Sdn Bhd, 13A, Subhash Road, Income Road No. 11, Barijara Hills, Tax Officer, Dehradun-248001 Hyderabad-500034 (Appellant) (Respondent) Pan No. Aabci3002L Assessee By : Sh. Siddesh Choudhary, Adv. Revenue By : Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: These Revenue’S Twin Appeals

For Appellant: Sh. Siddesh Choudhary, AdvFor Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 44BSection 44DSection 9Section 9(1)Section 9(1)(vi)Section 9(1)(vii)

case, the CIT (A) has erred in law in allowing the appeal of the assessee by completely overlooking the amended provisions of section 9(1)(vii), 44AB, 44DA of the Act, which were applicable to the assessment year under consideration. 5. Whether on the fact and circumstances of the case ... were in relation to the exploration and production of oil and natural gas and did not fall within the definition of FTS under section 9(1) (vii) of the Act. Since the consideration received by the Appellant was covered by the exclusion provided in the definition of FTS for “mining

DCIT, Dehradun vs. Intecsea Asia Pacific Sdn Bhd, Hyderabad

The appeal of the assessee is allowed

ITA 152/DDN/2025[2016-17]Status: DisposedITAT Dehradun13 Jan 2026AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 152/Ddn/2025 : Asstt. Year: 2016-17 Ita No. 153/Ddn/2025 : Asstt. Year: 2018-19 Dcit, Vs Intecsea Asia Pacific Sdn Bhd, 13A, Subhash Road, Income Road No. 11, Barijara Hills, Tax Officer, Dehradun-248001 Hyderabad-500034 (Appellant) (Respondent) Pan No. Aabci3002L Assessee By : Sh. Siddesh Choudhary, Adv. Revenue By : Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing: 13.01.2026 Date Of Pronouncement: 13.01.2026 Order Per Satbeer Singh Godara: These Revenue’S Twin Appeals

For Appellant: Sh. Siddesh Choudhary, AdvFor Respondent: Sh. Mohan Lal Joshi, Sr. DR
Section 143(3)Section 44BSection 44DSection 9Section 9(1)Section 9(1)(vi)Section 9(1)(vii)

case, the CIT (A) has erred in law in allowing the appeal of the assessee by completely overlooking the amended provisions of section 9(1)(vii), 44AB, 44DA of the Act, which were applicable to the assessment year under consideration. 5. Whether on the fact and circumstances of the case ... were in relation to the exploration and production of oil and natural gas and did not fall within the definition of FTS under section 9(1) (vii) of the Act. Since the consideration received by the Appellant was covered by the exclusion provided in the definition of FTS for “mining

Kyocera Document Solutions Asia Limited (Formerly Known As Kyocera Mita Asia Limited), Hongkong vs. Assistant Commissioner of Income Tax, Circle Intt Tax 2(1)(2), Delhi

In the result, the appeal of the assessee in ITA No

ITA 1664/DEL/2025[2022-23]Status: DisposedITAT Delhi13 Jan 2026AY 2022-23

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Nethrapal, CIT-DR
Section 143(3)

allowed. 28. As far as the question of FTS in ground 3 is concerned, we find that FTS under Explanation 2 of section 9(1)(vii) of the Act and Article 13 of India-Hong Kong Double Tax Avoidance Agreement ('DTAA') means consideration for providing any managerial, technical or consultancy ... services (including the provision of services of technical or other personnel). Income Tax Act defines the FTS under Explanation 2 of section 9(1)(vii) of the Act as under: Income by way of fees for technical services payable by- [Explanation 2] - For the purposes of this clause, "fees

Kyocera Document Solutions Asia Limited, Hong Kong vs. ACIT Circle Int Tax 2(1)(2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 380/DEL/2023[2020-21]Status: DisposedITAT Delhi13 Jan 2026AY 2020-21

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Nethrapal, CIT-DR
Section 143(3)

allowed. 28. As far as the question of FTS in ground 3 is concerned, we find that FTS under Explanation 2 of section 9(1)(vii) of the Act and Article 13 of India-Hong Kong Double Tax Avoidance Agreement ('DTAA') means consideration for providing any managerial, technical or consultancy ... services (including the provision of services of technical or other personnel). Income Tax Act defines the FTS under Explanation 2 of section 9(1)(vii) of the Act as under: Income by way of fees for technical services payable by- [Explanation 2] - For the purposes of this clause, "fees

Kyocera Document Solutions Asia Ltd., (Formerly Known As Kyocera Mita Asia Limited), Hong Kong vs. ACIT, Circle International Tax 2(1)(2), Delhi

In the result, the appeal of the assessee in ITA No

ITA 3546/DEL/2023[2021-22]Status: DisposedITAT Delhi13 Jan 2026AY 2021-22

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Nethrapal, CIT-DR
Section 143(3)

allowed. 28. As far as the question of FTS in ground 3 is concerned, we find that FTS under Explanation 2 of section 9(1)(vii) of the Act and Article 13 of India-Hong Kong Double Tax Avoidance Agreement ('DTAA') means consideration for providing any managerial, technical or consultancy ... services (including the provision of services of technical or other personnel). Income Tax Act defines the FTS under Explanation 2 of section 9(1)(vii) of the Act as under: Income by way of fees for technical services payable by- [Explanation 2] - For the purposes of this clause, "fees

Sabre Marketing Nederland, Bv, Netherlands vs. ACIT, Circle-3(1)(2) Int. Tax., New Delhi

ITA 381/DEL/2021[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Ms. Ekta Jain, CIT DR
Section 143(3)Section 144C(5)Section 9Section 9(1)(vi)

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT

Sabre Marketing Nederland, Bv, Netherlands vs. ACIT, Circle- 3(1)(2), International Taxation, New Delhi

ITA 7534/DEL/2019[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Ms. Ekta Jain, CIT DR
Section 143(3)Section 144C(5)Section 9Section 9(1)(vi)

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT

Sabre Marketing Nederland, Bv, New Delhi vs. ACIT, Circle- 3(1)(2), International Taxation, New Delhi

ITA 410/DEL/2019[2015-16]Status: DisposedITAT Delhi07 Jan 2026AY 2015-16

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Ms. Ekta Jain, CIT DR
Section 143(3)Section 144C(5)Section 9Section 9(1)(vi)Section 9(1)(vii)

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT

Bombardier Transportation Gmmh, New Delhi vs. Addldirecoootor of Inomce-Tax (International Taxation), Range-1, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 4547/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Jan 2026AY 2009-10

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.5732/धिल्ली/2011(नि.व. 2008-09) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India Ltd., 3Rd Floor, B-Wing, Somdutt Chambers-I, Bhikaji Cama Place, New Delhi ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4547/धिल्ली/2017(नि.व. 2009-10) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India P. Ltd., Asset No. 2, 3Rd Floor, Novotel- Pullman Commercial Tower, Aero City, Delhi International Airport, New Delhi 110037 ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4511/धिल्ली/2017(नि.व. 2009-10) Deputy Commissioner Of Income Tax, (International Taxation), R. No. 409, E-2 Block, 4Th Floor, Civic Centre, Near Minto Road, ...... अपीलार्थी/Appellant New Delhi बिाम Vs. Bombardier Transportation Gmbh, C/Co Asa & Associates, K S House 118, Shahpur Jat, New Delhi 110049 ..... प्रनिवादी/Respondent Pan: Aadcb-4031-C

For Appellant: S/Shri Deepak Chopra, Anmol Anand &For Respondent: Ms. Ekta Jain CIT-DR &
Section 143(3)Section 234BSection 271(1)(c)

Accordingly, consideration received for cost centers A1, A3, A5 and A10 are in the nature of FTS, both as per the provisions of section 9(1)(vii) of the Act as well as Article 12(4) of India-Germany DTAA. To conclude her arguments, she submitted that design, plans, drawings ... findings of the CIT(A) in holding the payments as FTS as per Article 12(4) of India-Germany DTAA, as well as section 9(1)(vii) of the Act. 30. The ld. Counsel for the assessee submitted that the issue raised in the aforesaid grounds of appeal are identical

DCIT, Circle- 1(1)(2), Intl. Taxation, New Delhi vs. Bombardier Transportation Gmbh, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 4511/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Jan 2026AY 2009-10

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.5732/धिल्ली/2011(नि.व. 2008-09) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India Ltd., 3Rd Floor, B-Wing, Somdutt Chambers-I, Bhikaji Cama Place, New Delhi ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4547/धिल्ली/2017(नि.व. 2009-10) Bombardier Transportation Gmbh, C/O M/S. Bombardier Transportation India P. Ltd., Asset No. 2, 3Rd Floor, Novotel- Pullman Commercial Tower, Aero City, Delhi International Airport, New Delhi 110037 ...... अपीलार्थी/Appellant Pan: Aadcb-4031-C बिाम Vs. Assistant Director Of Income Tax, ..... प्रनिवादी/Respondent Circle 1(1), New Delhi आअसं.4511/धिल्ली/2017(नि.व. 2009-10) Deputy Commissioner Of Income Tax, (International Taxation), R. No. 409, E-2 Block, 4Th Floor, Civic Centre, Near Minto Road, ...... अपीलार्थी/Appellant New Delhi बिाम Vs. Bombardier Transportation Gmbh, C/Co Asa & Associates, K S House 118, Shahpur Jat, New Delhi 110049 ..... प्रनिवादी/Respondent Pan: Aadcb-4031-C

For Appellant: S/Shri Deepak Chopra, Anmol Anand &For Respondent: Ms. Ekta Jain CIT-DR &
Section 143(3)Section 234BSection 271(1)(c)

Accordingly, consideration received for cost centers A1, A3, A5 and A10 are in the nature of FTS, both as per the provisions of section 9(1)(vii) of the Act as well as Article 12(4) of India-Germany DTAA. To conclude her arguments, she submitted that design, plans, drawings ... findings of the CIT(A) in holding the payments as FTS as per Article 12(4) of India-Germany DTAA, as well as section 9(1)(vii) of the Act. 30. The ld. Counsel for the assessee submitted that the issue raised in the aforesaid grounds of appeal are identical

Bombardier Transportation Gmbh, New Delhi vs. ADIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 5732/DEL/2011[2008-09]Status: DisposedITAT Delhi07 Jan 2026AY 2008-09
Section 143(3)Section 234BSection 271(1)(c)

Accordingly, consideration received for cost centers A1, A3, A5 and A10 are in the nature of FTS, both as per the provisions of section 9(1)(vii) of the Act as well as Article 12(4) of India-Germany DTAA. To conclude her arguments, she submitted that design, plans, drawings ... findings of the CIT(A) in holding the payments as FTS as per Article 12(4) of India-Germany DTAA, as well as section 9(1)(vii) of the Act. 30. The Id. Counsel for the assessee submitted that the issue raised in the aforesaid grounds of appeal are identical

Iyogi Technical Services Private Limited, Delhi vs. DCIT, Delhi

In the result, the Revenue’s appeal is partly allowed as indicated above

ITA 323/DEL/2022[2012-13]Status: DisposedITAT Delhi05 Jan 2026AY 2012-13

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Gagan Kumar, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR
Section 143(2)Section 194(2)Section 195Section 9(1)(vii)

being satisfied. On the basis of above observation and relying on several case laws, the Assessing Officer held that the provisions of section 9(1)(vii) of the Act is also attracted. He also reproduced the master service agreement in his order and based on the scope of work mentioned ... conclusion that the services rendered are squarely covered by the definition of fees for technical services as per Explanation 2 to section 9(1)(vii) of the Act. Further he observed that if there is any doubt relating to chargeability of tax in India and whether the TDS is required

Addl. CIT, Special Range- 4, New Delhi vs. Iyogi Technical Services Pvt. Ltd., New Delhi

In the result, the Revenue’s appeal is partly allowed as indicated above

ITA 2064/DEL/2018[2013-14]Status: DisposedITAT Delhi05 Jan 2026AY 2013-14

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Gagan Kumar, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR
Section 143(2)Section 194(2)Section 195Section 9(1)(vii)

being satisfied. On the basis of above observation and relying on several case laws, the Assessing Officer held that the provisions of section 9(1)(vii) of the Act is also attracted. He also reproduced the master service agreement in his order and based on the scope of work mentioned ... conclusion that the services rendered are squarely covered by the definition of fees for technical services as per Explanation 2 to section 9(1)(vii) of the Act. Further he observed that if there is any doubt relating to chargeability of tax in India and whether the TDS is required

Bechtel Ltd, London vs. ACIT, Circle 1(1)(2), International Taxation, New Delhi

In the result, appeal of the assessee is allowed

ITA 756/DEL/2023[2020-21]Status: DisposedITAT Delhi31 Dec 2025AY 2020-21
Section 143(2)Section 143(3)Section 144C(13)Section 44DSection 9(1)(vii)

taxable in India as it has no Permanent Establishment (PE) in India. However, the AO was of the view that as per section 9(1)(vii) of the Act, consideration received by any non-resident taxpayer for rendering any technical, managerial or consultancy services shall quality as FTS and shall

Bechtel Limited, London vs. ACIT, Circle Int. Tax 1(1)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 1816/DEL/2022[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19
Section 143(2)Section 143(3)Section 144C(13)Section 44DSection 9(1)(vii)

taxable in India as it has no Permanent Establishment (PE) in India. However, the AO was of the view that as per section 9(1)(vii) of the Act, consideration received by any non-resident taxpayer for rendering any technical, managerial or consultancy services shall quality as FTS and shall

Acronis Asia Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )Range-1(1)(1), Mumbai

In the result, the appeal filed by the assessee is

ITA 2035/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Dec 2025AY 2022-23
Section 10(50)Section 143(3)Section 144C(13)

distribution arrangement and cannot, by any stretch of legal interpretation, be equated with rendition of technical services within the meaning of section 9(1)(vii) of the Act or Article 12 of the applicable tax treaties. 22. It is equally significant to note that the assessee does not distribute ... permanent establishment, the enquiry into domestic law provisions becomes largely academic. 45. Nevertheless, since extensive arguments have been advanced on the applicability of section 9(1)(vii) of the Act, we proceed to examine the issue even on a without-prejudice basis under the domestic law. 46. Section 9(1

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income Tax, Circle 16(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 351/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR
Section 143(3)Section 37(1)Section 40

Federal and state income tax accounting for audit assistance and preparation, The id AR argued that the payments made are not taxable under section 9(1)(vii) since Deloitte & Touche LLP, USA and Deloitte Tax LLP, USA have rendered professional services and not technical services and drew our attention