Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI
364 ITR 256 (Del) ITA 621/2017 & connected matters Page 53 of 85 and confidentiality of MSAS services. We do not agree with the ruling of AAR that the stewardship activity would fall under Article 5(2)(l). To this extent we find merit in the civil appeal filed by the appellant (MSCo) and accordingly its appeal to that extent stands