2014 (7) TMI 1153

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..... l [2011 (9) TMI 1006 - ITAT MUMBAI] has assigned cogent and satisfactory reasons as to why the Assessing Officer could not have undertaken the exercise in the limited jurisdiction. Even otherwise, on merits as well, the Tribunal's view cannot be said to be perverse. The Tribunal in the peculiar facts and considering the double taxation avoidance agreement rendered a finding as to the interest on i .....

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..... assessee's appeal for the assessment year 2003-04 does not raise any substantial question of law. The Tribunal has assigned cogent and satisfactory reasons as to why the Assessing Officer could not have undertaken the exercise in the limited jurisdiction. Even otherwise, on merits as well, the Tribunal's view cannot be said to be perverse. The Tribunal in the peculiar facts and conside .....

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