ORDER

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of ADDL/JCIT (A)-2 NOIDA, vide order no. ITBA/APL/S/250/2024- 25/1070036124(1), dated 30.10.2024, passed against the assessment order by Assistant Commissioner Of Income Tax, Circle 20(3), Mumbai, u/s. 143(3) of the Income-tax Act (hereinafter referred to as the “Act”), dated 30.12.2019 for Assessment Year 2017-18.

2. Grounds taken by assessee are reproduced as under:

“1. On the facts and in the circumstances of the appellant company's case and in law, the Ld. Addl./ Jt. Commissioner of Income Tax (Appeals) - 2, Noida, has erred in not quashing the assessment order passed on 30.12.2019 by the Assessing Officer w/s 143(3) of the Income Tax Act, 1961.

2. On the facts and in the circumstances of the appellant company's case and in law, the Ld. Addl./Jt. Commissioner of Income Tax (Appeals) -2, Noida, erred in upholding the disallowance of Rs 2,13,66,955/- u/s 40(a)(ia) of the Act for non- deduction of TDS on "Fees for technical services" paid to three non-residents while ignoring the fact that:

(a) The services rendered by the non-resident consultants constitute professional and consultancy s