TMI Blog2012 (5) TMI 682X X X X Extracts X X X X X X X X Extracts X X X X ..... sh Kumar. ORDER PER BENCH : These are cross appeals by the assessee and department directed against the order of CIT(A)-XXXIII, Mumbai, dated 10-03-2008 in relation to assessment year 2004-05. 2. We shall first take up the assessee s appeal in ITA No.3832/Mum/2008. 3. Ground nos. 1 2 are on the issue as to whether the assessee had a permanent establishment in India. Consis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e allow this ground of the assessee. 7. Ground no.6 is on the issue of disallowance u/s. 40(a)(i) on payment made to LMB Holdings Ltd. (Isle of Man) for purchase of films. This issue is the same as the issue at ground no. 6 for the assessment year 2002-03. Consistent with the view taken therein, we allow this ground of the assessee. 8. In the result, the appeal of the assessee is allowed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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