TMI Blog2011 (3) TMI 1819X X X X Extracts X X X X X X X X Extracts X X X X ..... cate ORDER PER BENCH: 1. All these four appeals by the revenue and four cross objections of the assessee are directed against the combined order of Ld. CIT(A)- XXIX, New Delhi dated 11.02.2010 for the assessment years 1999-2000 to 2002-03. For the sake of convenience, all these appeals and cross objections are being disposed of by this common order. 2. At the outset, it was subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r 1995-96 to 1998-99, similar issue in assessee s own case was decided by the tribunal and it was held that only 15% of the revenue generated for the booking made within India can be considered as attributable to the PE in India and hence only 15% of the revenue generated from the booking made within India is taxable in India. It was also held by the tribunal that since the payment to the agents i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to 1998-9. He submitted a copy of tribunal decision in assessee s own case for these assessment years 1995-96 to 1998-99 in I.T.A. Nos. 1733/D/2001, 2473-2475/D/2000 and 820-823/D/2005 and C.O. No.47 to 54/D/2006 dated 30.11.2007. It is also submitted that against this tribunal order, both the assessee and revenue were in appeal before Hon'ble High Court of Delhi. It is submitted that revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Hon'ble High Court of Delhi rendered in the assessee s appeals as well as revenue s appeals. Ld. DR also agreed that these issues are covered as per these judgements. 5. We have considred the above factual and legal position and we find that only one issue is involved in the appeals of the revenue that whether the Ld. CIT(A), was Justified in holding that only 15% of the revenue is income a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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