9911796707
TMI Blog2015 (11) TMI 1687X X X X Extracts X X X X X X X X Extracts X X X X ..... t : Mr. Kamal Sawhney, Senior Standing Counsel, Mr.Raghvendra Singh, Junior Standing Counsel and Mr. Shikhar Garg, Advocate. For the Respondent : Mr. C.S. Aggarwal, Senior Advocate with Mr. Rajiv Saxena, Advocate and Mr. Shaswat Bajpai, Advocate. O R D E R 1. These appeals by the Revenue under Section 260A of the Income Tax Act, 1961 are directed against the order dated 31st July 2009 passed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 147 of the Act and the consequent reopening of the assessment under Section 148 of the Act. 4. Aggrieved by the order dated 31st July 2009 to the extent the ITAT negatived the above plea, the Assessee filed appeals before this Court being ITA Nos. 98, 101,102,105 and 106 of 2012. The said appeals were by order dated 6th February 2012 permitted by this Court to be treated as cross-o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er dated 11th December, 2008 passed by the High Court (ii) Whether the ITAT was right in treating the licence fee as an accrued liability? 7. As far as, question (i) above is concerned, a further question that would arise is: what should be the consequence, if the said question is answered in the negative i.e., if the Court holds that the ITAT's impugned order dated 31st July 2009 does not deci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... considered in these appeals of the Revenue as well as the cross-objections of the Assessee are reframed as under: (i) Whether the order dated 31st July 2009 of the ITAT is in conformity and decides all the aspects/issues remitted to it by order dated 11th December 2008 passed by this Court? (ii) If the answer to the above question is in the negative, was the assumption of jurisdiction under S ..... X X X X Extracts X X X X X X X X Extracts X X X X
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