In the result, Appeals of the Revenue's are dismissed\nOrder pronounced in the open court on\nSd/-\n(MANISH AGARWAL)\nACCOUNΤΑΝΤ ΜΕMBER\nDate: 28

capital tools M.E. Ltd.\nunder the head \"Salaries\".\nThe assessee does not get the benefit of exclusionary clause 2 of sec.\n9(1)(vii) since this activity executing annual maintenance contract and\nconsultancy is not a mining activity and is purely technical service.\nSimilarly, these nature of activities are not covered under provisions of\nsec. 44BB and royalty in nature