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TMI Blog2014 (10) TMI 858X X X X Extracts X X X X X X X X Extracts X X X X ..... art of ‘export turnover’ within the meaning of Explanation 2 to Section 10A? - Held that:- This Court had an occasion to consider the substantial questions of law in the case of The Commissioner of Income Tax & another v/s. Motor Industries Co. Ltd. [2015 (7) TMI 876 - KARNATAKA HIGH COURT ], wherein it was held that if the technical services rendered by the assessee’s engineers is in connection w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llant BY SRI: CHYTHANYA K K, ADVOCATE Respondent BY SRI: JEEVAN J NEERALGI, ADVOCATE JUDGEMENT This appeal is by the assessee challenging the order passed by the Tribunal. 2. The substantial questions of law that are raised in this appeal are, i) On the facts and circumstances of the case whether the Appellate Tribunal is right in holding that the appellant is rendering te ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erred in holding that the order of the Tribunal in the case of M/s.Infosys Technologies Ltd. in ITA No.1022 1130/Bang/2003 dated 7.4.2006 is not applicable to the appellant s case? 3. Insofar as substantial questions of law 1, 2 and 4 are concerned, they are interconnected. This Court had an occassion to consider the substantial questions of law in the case of The Commissioner of Income Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the case of the assessee itself, in I.T.A.No.411/2008, we have answered the similar substantial question in favour of the assessee and against the revenue. Accordingly, the said substantial question is also answered in favour of the assessee and against the revenue. 5. Hence, we pass the following order. The appeal is allowed. Impugned orders passed by the authorities are hereby set aside. T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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