2014 (3) TMI 815

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..... lis. 2. Leave granted. 3. The following questions of law were raised by the appellant before the High Court: "i) Whether on the facts and in the circumstances of the case and in law, the Tribunal erred in holding that the procurement fees of Rs.5.30 crores payable of M/s Tech Source Corporation is not liable to be taxed in India under Section 9(1)(i) or 9(1)(vii) and further erred in holding t .....

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..... the substantial questions of law raised by the revenue. 5. In view of the above, we allow this appeal and set aside the judgment and order passed by the High Court. We remand the matter back to the High Court and request the High Court to consider and decide the aforesaid questions of law taking into consideration the provisions of Section 260A of the Act.   6. We clarify that we have not .....

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