2005 (11) TMI 494

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..... CE D.A.MEHTA) 1 The appellant-revenue has proposed the following two questions : "[A] Whether the Appellate Tribunal is right in law and on facts in holding that pursuant to the agreement executed for transfer of marketing rights to Neumetic Marketing Co.Pvt.Ltd., no receipts were received or accrued to the assessee and thereby confirming the order passed by the CIT(A) deleting the disallowance .....

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..... ed by the assessee in the year under consideration and in light of the agreement being effective after the end of the accounting period no payment had accrued to the assessee. 4 Once it is found by the appellate authority that on facts the agreement had never come into operation in the accounting year it cannot be stated that the authorities have erred, in any manner whatsoever, in holding that t .....

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