2012 (3) TMI 579

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..... with Mr. Satyen Sethi, Mr. Arta Trana Panda and Mr. Rahul Sateeja, Advocates. O R D E R C.M.No.16498/2011 This is an application for condonation of delay in refiling. As there is no objection from the assessee, the application is allowed and the delay in refilling is condoned. ITA 1058/2011 Heard. Admit. The following substantial questions of law are framed:- .....

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..... right in law in holding that subjecting the assessee to tax on gross basis would be tantamount to discrimination vis-a-vis an India company carrying on the same business, within the meaning of Article 26 of DTAA between India and UK? (5) Whether on the facts and circumstances of the case, the ITAT was right in holding that interest income earned by the assessee outside India (although from fund .....

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