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2025 Supreme(Online)(ITAT) 6520

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI ANUBHAV SHARMA, JM, SHRI MANISH AGARWAL, AM
Subramaniam Hariharan – Appellant
Versus
ACIT – Respondent


Advocates:
For the Appellants/Petitioners: Shri Ajay Vohra, Shri Neeraj Jain, Shri Aditya Vohra, Shri Arpit Goyal
For the Respondents: Ms Tanya Sharma

Table of Content
1. tax implications of payments for international legal services. (Para 2 , 3)
2. arguments on the classification of services and tax obligations. (Para 4 , 5 , 6)
3. court's observations on the nature of professional vs technical services. (Para 8 , 9 , 11)
4. judgment affirming distinction in service classifications under tax law. (Para 18 , 19 , 20)

ORDER

PER ANUBHAV SHARMA, JM

The ITA Nos.600/Del/2020 and 9832/Del/2019 are cross appeals preferred by the Revenue as well as the assessee Subramaniam Hariharan, respectively, against the order dated 29.11.2019 of the Ld. Commissioner of Income-tax (Appeals)-43, New Delhi (hereinafter referred to as the Ld. First Appellate Authority or ‘the Ld. FAA’, for short) in Appeal No.10031/2019-20 arising out of the appeal before it against the order dated 22.03.2016 passed u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) by the ACIT, Circle 63(1), Delhi (hereinafter referred to as the Ld. AO) and the No.2134/Del/2018 is the appeal preferred by the assessee, Anand and Anand against the order dated 18.01.2018 of the Ld. FAA in Appeal No.18/10496/2016-17/248 arising out of the appeal before it against t

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