TMI Blog2013 (1) TMI 936X X X X Extracts X X X X X X X X Extracts X X X X ..... enue for assessment year 19971998, the following questions of law have been formulated for our consideration. a) Whether on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the profit arising on the offshore supply contract to MRPL cannot be taxed in India under the provision of Section 9 of the Income Tax Act, 1961 ? b) Whether, on the f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rder were challenged by the Revenue before this Court in Income Tax Appeal No.1033 of 2011 (Siemens Aktiengesellschaft) and in Income Tax Appeal No.825 of 2010 (M/s.Xelo Pty. Limited), were dismissed by this Court on 20th November 2012 and 15th November 2011 respectively. Therefore, according to the respondent assessee question (a) as raised does not arise for consideration. However, Mr.Tejveer Si ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ), question (a) as proposed cannot be entertained. 3. So far as question (b) is concerned, both the Commissioner of Income Tax (A) as well as the Tribunal have reached a finding of fact that the respondent assessee was maintaining regular books of account and had even submitted the same to the assessing officer for verification, who also verified the same. Consequently, both the Commissioner of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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