9911796707
TMI Blog2014 (10) TMI 360X X X X Extracts X X X X X X X X Extracts X X X X ..... ave not been acquired by the assessee - There is what is termed as registered user agreement - the rights conferred have been looked as inconclusive and enduring in nature, that the findings of facts rendered by the tribunal cannot be termed as perverse - AO has erroneously assumed that the trade mark has been acquired by the assessee by the arrangement brought to his notice - the tribunal did not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to this Court being Income Tax (L) No.3600/2008, 3601/2008 and 3605 of 2008. These appeals were brought by the Revenue and to challenge the findings in the order of the Income Tax Appellate Tribunal for the assessment years 1994-95, 19995-96 and 1996-97. These appeals have been dismissed by this Court as being barred by limitation. The order in that behalf was challenged before the Supreme Court a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... invoked by Mr.Irani. 5. However on careful perusal of the order of the Tribunal impugned in this appeal and in the light of the questions raised we are unable to accept the arguments of Mr.Pinto. 6. Insofar as the first question is concerned, the tribunal has reversed the findings in the order of the Joint Commissioner and to the extent indicated in the impugned order by looking at the agree ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as perverse. The Assessing Officer has erroneously assumed that the trade mark has been acquired by the assessee by the arrangement brought to his notice. Having analysed that arrangement accordingly and as a whole, the tribunal arrived at the above factual finding. In the light of the material placed on record such finding cannot be termed as perverse or vitiated by any error of law apparent on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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