The Supreme Court allowed to issue notice under SLP filed by the assessee challenging the order of the Hon. Bombay High which held that since the payment made for transponder services post Finance Act,2012  and neither the  Assessing officer, CIT(A) or Hon. ITAT have examined and analysed the nature of services as agreed upon by the parties in the agreement and have not given finding on the facts on the issue involved nor has discussed how the said payment is under Article 12(3) of the Treaty and orders were non-speaking orders the matter is remanded back to CIT(A) for finding the facts. Hon. Supreme could also ordered for stay of the order of Hon. Bombay High Court. (AY. 2009-10 to 2013-14)