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TMI Blog2023 (1) TMI 723X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal on the question, whether the Jammu Unit had utilized the technical know-how provided to the respondent assessee company under the MoUs. Till this core and important aspect and question is decided, we cannot proceed and decide, the other question whether the expenditure on royalty was incurred by the Jammu Unit or the Corporate Office. In view of the aforesaid finding in the appeal filed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AND HON'BLE MS. JUSTICE TARA VITASTA GANJU Appellant: Mr Abhishek Maratha, Sr Standing Counsel. Respondent: Mr M P Rastogi with Mr Manu K Giri and Mr K N Ahuja, Advs. ORDER RAJIV SHAKDHER, J. CM Appl.14798/2019 in ITA 308/2019 1. This is an application filed on behalf of the appellant/revenue seeking condonation of delay in refiling the appeal. 2. Accordin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Court answered, were the following: 1. Whether assessee was right in reallocating expenditure/income on account of royalty from Jammu Unit to Corporate Division? 2. If the answer to the above is in the affirmative in favour of the Revenue, the further question which arises is whether the Assessee was entitled to deduction under Section 80-IB of the Income Tax Act, 1961 in respect of sub ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Appeals), allowing netting of royalty received from royalty paid for computation of deduction under Section 80-IB of the Act. As we have remanded the issue of deduction under Section 80-IB, it will be open to the Assessee to press their cross appeal before the Tribunal in case of an adverse finding against the assessee on the first issue. 23. The substantial questions of law are accordingly a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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