2019 (8) TMI 1856

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..... to this Court [ 2018 (3) TMI 1991 - BOMBAY HIGH COURT] raising this very issue. This Court s order did not entertain this question as proposed therein on the grounds that the same in the facts of the case was academic in nature. This for the reason what was being paid by the Indian entity to its Singapore branch was only in the nature of reimbursement of expenses. This finding of fact was not .....

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..... ome Tax Appellate Tribunal, Mumbai ( Tribunal ). The Appeals relate to Assessment Years 2008-09 and 2009-10. Thus the two Appeals. 3. Ms.Bharucha, learned counsel appearing in support of these Appeals urges only the following question of law for our consideration. Whether on the facts and in the circumstances of the case and in law, the Tribunal has erred in holding that the data processing .....

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..... es. This finding of fact was not challenged in the Revenue s appeal for Assessment Year 2006-07 or in these appeals for Assessment Year 2008-09 and 2009-10. The Revenue has not been able to show any difference in facts and/or in law in the subject Assessment Years to that in Assessment Year 2006- 07. Therefore, the above decision of this Court for Assessment Year 2006-07 will apply in these two Ap .....

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