TMI Blog2008 (12) TMI 755X X X X Extracts X X X X X X X X Extracts X X X X ..... t / assessee. 4th December, 2008 These appeals pertain to assessment year 1994-95 and 1995-96. In both the appeals following substantial question arises to be considered: Whether the Hon ble I.T.A.T. was legally correct in holding that no portion of the payment made to the NRC outside India for the work done outside India under the composite contract for designing fabrication, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... icularly, when the appeal is in respect of the assessment years 1987-88 and 1988-89. 3. Therefore, in view of the two answers given in Clause (a) and (b) of Paragraph 15 of the aforesaid judgment, the matter is remitted to the ITAT for deciding the same afresh in the light of Clause (a) and (b) of Paragraph 15 of CIT V. Hyundai Heavy Industries Co. Ltd. [2007] 291 ITR 482 (SC) applying the ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
