Assessee company was engaged in business relating to online advertising like internet based content, communications, etc.  It claimed deduction on account of selling and marketing expenses paid to its US subsidiary for rendering services in nature of targeting new customers, carrying out promotional activities and participating in trade shows outside India on behalf of assessee. Assessing Officer held that impugned payments had been made for rendering of managerial, technical or consultancy services and payment was in nature of Fee for Technical Services. Commissioner (Appeals) held that payment for market analysis, maintenance of online data, customer database, etc., was in nature of royalty. Tribunal held that nature of services provided by US subsidiary had not been analysed by Commissioner (Appeals) and Commissioner (Appeals) had rendered decision without bringing on record supporting material. Accordingly the matter remanded to the Commissioner (Appeals). (AY. 2014-15 to 2016-17)