Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh
iv) Whether on the facts and in the circumstances of the case and in law, the CIT (A) has erred in ignoring the nature of activities and scope of work in respect of the Annual Maintenance Contract Services, support for software and training, etc provided by the assessee lead to the infallible conclusion that the receipts of the assessee were