ITAT Remand Back Case to CIT(A) for analysis of Nature of Service

Adadyn Technologies Private Limited Vs DCIT (ITAT Bangalore) The issue under consideration is whether assessee engaged in business relating to online advertising is considered as technical services or royalty Section 9(1)(vii) of the Income Tax Act, 1961? ITAT states that, the AO has mainly placed reliance on the provisions of sec.9(1)(vii) of the Act, though he has made reference to DTAA at some place. ITAT notice that the AO has not properly analysed the nature of services rendered in the context of sec. 9(1)(vii) or DTAA, even though he has extracted the agreement entered between the assess...