TMI Blog2013 (5) TMI 1006X X X X Extracts X X X X X X X X Extracts X X X X ..... or the parties. The revenue has proposed the following questions as substantial questions of law:- 1. Whether the Income Tax Appellate Tribunal was correct in law and on facts in deleting the addition on account of technical know-how of ₹ 61,20,05,000/- and royalty of ₹ 81,71,60,464/- paid by the assessee to Honda Motor Co. Ltd. 2. Whether the Income Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... far as proposed question No. 2 is concerned, that issue stands covered in favour of the respondent / assessee by virtue of the decision of the Supreme Court in the case of CIT v. Samtel Color Ltd. decided in Civil Appeal No. 6448/2012 on 12.09.2012. Consequently that question does not arise any further. As regards proposed question No. 3, the issue is also covered in favour of the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X
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