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2015 (4) TMI 505 - KARNATAKA HIGH COURTIncome derived through operations as Liaison office in India - purchase of goods in India for the purpose of export - Entitlement of exemption provided in explanation 1(b)to section 9(1)(i) of the Act - AO observed that the activities of the assessee relate to supply chain management activities for Tesco International Sourcing Ltd., Hongkong Company and is not covered in the exception provided in Explanation 1(b) to Section 9(1)(i) of the Act. - Held that:- The Tribunal at Para No.7.2 has clearly set out the facts of the Nike case as well as in this case and after applying the law laid down in the aforesaid case has granted the relief to the assessee. The factual positions are not disputed. Therefore, it is the judgment rendered by this Court in Nike's case [2013 (8) TMI 194 - KARNATAKA HIGH COURT] which is applicable to the facts of this case and the Tribunal has relied upon the said judgment and followed the same. No case is made out for interference as rightly pointed out by the Tribunal. - In that view of the matter, the substantial question of law raised is answered in favour of the assessee and against the revenue. - Decided against the revenue.
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