2010 (8) TMI 761

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..... ondent. ORDER Pramod Kumar, Accountant Member. - The short grievance raised in this miscellaneous application is that the Tribunal, while disposing of the appeal vide order dated 20-4-2007, did not dispose of the following additional ground of appeal : On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred, inter alia, in not appreciating that :-- I.the asse .....

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..... nternational Taxation) v. Morgan Stanley & Co. [2007] 292 ITR 416 , and since the assessee has paid arms length remuneration for services of its Indian agent, no further profits can be attributed to the foreign enterprise in India under article 7(1) of,India Singapore Double Taxation Avoidance Agreement. Their Lordships have also relied upon CBDT circular No. 23 to come to this conclusion. 4. In .....

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