AAR rejected applications as issues raised by assessee was already pending before AO

INCOME TAX : Where applicant had entered into a Project Management Consulting Agreement (GSPC) for providing feed review services, preparation of request for proposal documents, assistance in bidding process, cost estimation services, construction supervision etc. in relation to construction of marine, regas and tank facilities by GSPC and he seeks to know as to whether sums received by applicant under (PMC Agreement) is liable to tax as fee for technical services under Article 13

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