2012 (7) TMI 1125

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..... PER Dr.O.K.NARAYANAN, VICE-PRESIDENT: These two appeals are filed by the Revenue. The relevant assessment years are 2005-06 and 2006-07. These appeals are directed against the common order passed by the Commissioner of Income-tax(Appeals)-IV at Chennai, dated 1-11-2011, and arise out of the assessments completed under section 143(3) of the Income-tax Act, 1961. 2. The common ground raise .....

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..... ndia Ltd., 330 ITR 175. 5. The Hon ble Delhi High Court also has taken a similar view in the case of CIT vs. Genpact India, decided on 16th November, 2011. 6. This issue was in fact determined as early as on 6th March, 2009 by the Special Bench of the Income-tax Appellate Tribunal, Chennai, in the case of ITO vs. Sak Soft Ltd., 313 ITR (AT) 353 (Chennai) (SB). 7. In view of the above, the .....

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