1998 (6) TMI 567

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..... the 'Act'), the Tribunal has referred the following two questions of law to this Court at the instance of the assessee for opinion. (i) Whether the amount of ₹ 9,28,328 representing fee for use of manufacturing know-how and for necessary training of the applicant's personnel outside India, paid to Ciba Geigy Ltd., Basle, Switzerland, was allowable as a deduction for the asst. .....

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..... the parties are further agreed that question No. 2 is covered by this Court's decision in the case of Lubrizol India Ltd. vs. CIT (1991) 93 CTR (Bom) 237: (1991) 187 ITR 25(Bom) : TC 18R.632, and the decision of the Supreme Court in the case of Smith Kline French (I) Ltd. vs. CIT (1996) 132 CTR (SC) 500: (1996) 219 ITR 581(SC), and following the same it should be answered in the affirmative .....

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