TMI Blog2022 (9) TMI 1563X X X X Extracts X X X X X X X X Extracts X X X X ..... #39; as defined under Section 9(1)(vi) of the Income Tax Act, 1961 ( the Act ) and Article 12(3) of the India-Swiss DTAA. HELD THAT:- Admittedly, the questions of law urged in the present appeal are covered by the decision of the Supreme Court in the case of Engineering Analysis Centre of Excellence Pvt. Ltd. [ 2021 (3) TMI 138 - SUPREME COURT] wherein held amounts paid by resident Indian end- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... td. Vs. Church of South India Trust Association CSI Cinod Secretariat, Madras ( 1992 (4) TMI 183 - SUPREME COURT ) the present appeal is covered by the judgment of the Supreme Court in Engineering Analysis (supra). No substantial question of law. - Manmohan And Ms. Manmeet Pritam Singh Arora JJ. For the Appellant : Ms. Easha Kadian , Advocate, for Sanjay Kumar , Senior Standing Counsel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 471(SC). 4.3 The Ld. DR did not refute the claim of the Appellant. 4.4 We have given thoughtful consideration to the submissions of the Appellant and perused the order and judgment as referred above by the Appellant and observed that the issues under consideration as raised vide grounds no. 3 and 4 in this appeal, are identically the same, as have been decided by the Hon ble Tribunal in Appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 ITR 471 SC. 4. At this stage, learned Counsel for the Appellant states that the revenue has not accepted the decision in Engineering Analysis (supra) and has preferred a review petition against the same. 5. Though the review petition in Engineering Analysis (supra) is pending before the Supreme Court, yet there is no stay of the said judgment till date. 6. Consequently, in view of the j ..... X X X X Extracts X X X X X X X X Extracts X X X X
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