ATOMSTROYEXPORT ,MUMBAI vs. DCIT (IT)CIRCLE -1(1)(2), MUMBAI
In the result, the appeal of the assessee is allowed
ITA 575/MUM/2023[2020-2021]Status: DisposedITAT Mumbai12 Dec 2023AY 2020-2021
Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am
For Respondent: Shri Ajay Kumar Sharma, CIT-DR
Section 143(3)Section 234ASection 234BSection 44B
assessee should not have been tax under section 44BBB of the Act but should have been taxed as fee for technical service under section 91(1)(7) of the Act. The ld. DR in this regard presented a detailed written submission and also arguments during the course of hearing
