9911796707
TMI Blog2018 (3) TMI 1588X X X X Extracts X X X X X X X X Extracts X X X X ..... ax Act, 1961 (the Act) challenges the order dated 29th September, 2014 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order is in respect of Assessment Year 2007-08. 2. The Revenue urges the following questions of law for our consideration :- i) Whether in the facts and circumstances of the case and in law, the Tribunal was correct in excluding Informed Technologies Ind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he year under consideration and had any bearing on the functionality or margins of the company? 3. Regarding question no.(i) :- a) We have today passed an order in Income Tax Appeal No.1095 of 2015 filed by the Revenue in respect of the same respondent assessee arising from the common impugned order dated 29th September, 2014 to the extent it related to A.Y. 2008-09. In our order in the above ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ondent earned taxable income in the form of royalty from Cummins India as well as IT enabled services from its India branch. The India branch of the respondent assessee is a 100% export oriented unit and renders support services in the area of finance, human resources, marketing database support, product management support, procurement/supply chain management support, information technology servic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ctional difference between the two. (c) The view taken by the Tribunal on the facts is a reasonable and possible view. Therefore, the question as proposed does not give rise to any substantial question of law. Thus, not entertained. 5. Regarding Question no.(iii) :- (a) We find that the impugned order of the Tribunal has placed reliance upon the decision of the Delhi Bench of the Tribunal in th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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