2016 (1) TMI 1424

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... o frame a question of law on this issue. Addition u/s 40(a) (ia) - export commission is neither royalty nor fee for technical service - HELD THAT:- As far as Question (2) is concerned, learned counsel for the Revenue states that he would like to address arguments on the next date. - ITA 538/2015 - - - Dated:- 14-1-2016 - S.Muralidhar And Vibhu Bakhru, JJ. Mr. Kamal Sawhney, .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... or fee for technical service? 3. As far as Question (1) is concerned, it has been answered in favour of the Assessee in Assessee s own case CIT v. Hero Honda Motors [2015] 372 ITR 481 (Del.) The Court, accordingly, declines to frame a question of law on this issue. 4. As far as Question (2) is concerned, learned counsel for the Revenue states that he would like to address argume .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X