9911796707
TMI Blog2015 (4) TMI 505X X X X Extracts X X X X X X X X Extracts X X X X ..... Respondent : K.R. Vasudevan and P. Dinesh, Advocates JUDGMENT 1. As a common question of law arises for consideration in all these appeals and the assessee is also the same and the orders are passed in respect of different assessment years, they are taken up for consideration together and disposed of by this common judgment. 2. The revenue has preferred these appeals against the common order p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . The survey was conducted under Section 133A of Income Tax Act (hereinafter referred to as Act) on 05.02.2009 in the office premises of the assessee. In compliance of the notice under Section 148 of the Act dated 26.05.2009, the assessee filed its returns of income for the assessment years 2005-2006 on 02.07.2009 admitting Nil income. After processing the said returns, the Assessing Authority hel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e two judgments of this Court in the case of CIT (International Taxation) v. Nike Inc., reported in [2013] 34 taxmann.com 170(Karnataka) and also in the case of Jebon Corpn. India Liaison Office v. CIT (International Taxation) & ANR. repored in (2011) 245 CTR (Kar) 300 and held that, the facts of this case are similar to the one in the case of Nike and therefore following the said judg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... applicable to the facts of this case. In fact, in para No.7.5 the Tribunal has also taken note of the judgment of this Court in Jebon Corpn. India Liaison Office (supra) holding that the law laid down was not applicable to the facts of this case. Therefore he submits that no case for interference is made out. 8. The substantial question of law raised in these appeals for consideration of this Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it is the judgment rendered by this Court in Nike's case (supra) 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. The facts in the case of the Jebon Corpn. India Liaison Office (supra) is totally different from the facts of this case and said judg ..... X X X X Extracts X X X X X X X X Extracts X X X X
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