1998 (6) TMI 567

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..... ence under s. 256(1) of the IT Act, 1961 (the 'Act'), the Tribunal has referred the following two questions of law to this Court at the instance of the assessee for opinion. "(i) Whether the amount of ₹ 9,28,328 representing fee for use of manufacturing know-how and for necessary training of the applicant's personnel outside India, paid to Ciba Geigy Ltd., Basle, Switzerlan .....

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..... in favour of the assessee. 3. Counsel for the parties are further agreed that question No. 2 is covered by this Court's decision in the case of Lubrizol India Ltd. vs. CIT (1991) 93 CTR (Bom) 237: (1991) 187 ITR 25(Bom) : TC 18R.632, and the decision of the Supreme Court in the case of Smith Kline & French (I) Ltd. vs. CIT (1996) 132 CTR (SC) 500: (1996) 219 ITR 581(SC), and following the sa .....

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