Illustrations : SLP dismissed against impugned order of High Court that where assessee, a company, was engaged in business of providing security services to its clients and it was paying service tax on behalf of its clients to Government and recovering same from them, said amount could not be included in ‘fee for technical services’ (FTS) while computing disallowance under section 40(a)(ia) – Mark Gulati v. Principal Commissioner of Income-tax – [2024] 164 taxmann.com 604 (SC)