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TMI Blog2015 (4) TMI 505X X X X Extracts X X X X X X X X Extracts X X X X ..... g the law laid down in the aforesaid case has granted the relief to the assessee. The factual positions are not disputed. Therefore, it is the judgment rendered by this Court in Nike's case [2013 (8) TMI 194 - KARNATAKA HIGH COURT] which is applicable to the facts of this case and the Tribunal has relied upon the said judgment and followed the same. No case is made out for interference as rightly pointed out by the Tribunal. - In that view of the matter, the substantial question of law raised is answered in favour of the assessee and against the revenue. - Decided against the revenue. - ITA Nos. 231/2014 C/w, ITA Nos. 231, 232, 233 & 235 of 2014 - - - Dated:- 5-1-2015 - N. KUMAR AND B. VEERAPPA, JJ. For The Appellant : K.V. Aravind, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e for the assessment years 2005-2006 on 02.07.2009 admitting Nil income. After processing the said returns, the Assessing Authority held the activities of the assessee relate to supply chain management activities for Tesco International Sourcing Ltd., Hongkong Company and is not covered in the exception provided in Explanation 1(b) to Section 9(1)(i) of the Act. Accordingly, assessment order is passed levying tax. Aggrieved by the said order, the assessee preferred an appeal against the draft assessment order. 4. The assessee filed its objections to draft assessment order before the Dispute Resolution Panel. The Dispute Resolution Panel confirmed the view taken by the Assessing Authority. Thereafter, the Assessing Authority proceeded to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is Court in Jebon Corpn. India Liaison Office (supra) holding that the law laid down was not applicable to the facts of this case. Therefore he submits that no case for interference is made out. 8. The substantial question of law raised in these appeals for consideration of this Court is as under: Whether on the facts and in the circumstances and in Law, the Tribunal was correct in holding that the activity of the liaison office of the assessee is confined to purchase of goods in India for the purpose of export, when the assessee is carrying on the systematic activity of business and earning income through its liaison office and liable to tax u/s.9(1)(i) of the Act and recorded a perverse finding? 9. We have gone through the impu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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