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TMI Blog2019 (1) TMI 1346X X X X Extracts X X X X X X X X Extracts X X X X ..... (IT)-1, Vs. Deutsche Bank [2016 (11) TMI 1600 - BOMBAY HIGH COURT] rendered wherein an identical question raised by the Revenue was dismissed by following the earlier decision of this Court in the case of CIT Vs. Bank of India [1995 (11) TMI 78 - BOMBAY HIGH COURT]. Thus, this question as proposed does not give rise to any substantial question of law, hence, not entertained. Non-resident asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mstances of the case and in law, the Tribunal was correct in holding that Section 44C is not applicable in respect of Head Office Expenses and such expenses are to be dealt with as per Article 7? - Income Tax Appeal No. 942 of 2016 - - - Dated:- 21-1-2019 - AKIL KURESHI M.S. SANKLECHA, JJ. Mr. Tejveer Singh for the Appellant Mr. Percy Pardiwalla, Sr. Counsel a/w Mr. Atul Jasani for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ount of unmatured forwarded foreign exchange transaction being an unascertained liability? (iii) Whether on the facts and circumstances of the case and in law, a non-resident assessee has to exercise an option to be assessed under provisions of the Income Tax Act (or) as the came may be the provisions contained in the applicable DTAA and if the option has to be exercised, whether the non-resi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... impugned order of the Tribunal. Mr. Tejveer Sing, the learned counsel for the Revenue is unable to point out consideration of this question by the Tribunal. It appears that this question was not even urged before the Tribunal. Thus, no occasion to consider the aforesaid question, hence, not entertained. 5. The appeal is admitted only on Question No. 1 which is a substantial question of law. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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