1990 (8) TMI 57

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..... ught to be raised are : "(i) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in cancelling the order passed by the Commissioner of Income-tax under section 263 of the Income-tax Act ? (ii) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the receipt by way of service fees by the assessee from BAS .....

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..... However, the Department has raised only one question regarding the applicability of the provisions of the Double Taxation Avoidance Agreement. It is evident that even if this question is answered in favour of the Department, the result of the appeal will not be altered. The question is thus academic. No useful purpose will be served in directing the Tribunal to state the case. Rule is, according .....

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