In an appeal filed before by the Revenue, the ITAT relied on the decision of CIT v. Liquid Investment and Trading CO. (ITA No. 240/2009) and held that since the issue involved in the present appeals was debatable and since a substantial question of law had been framed by the Delhi High Court in the quantum appeal filed by the assessee, the penalties imposed in both AYs were not exigible and dismissed the said appeals.  Editorial note: The Delhi High Court held that fees received by the assessee for providing domain name registration services were not taxable as a royalty because the U.S. company was merely acting as a registrar and it did not have any proprietorship rights in the domain name and could not grant the rights or transfer the right to use the domain name to another person or entity.(AY. 2013-14 2014-15)