Being aggrieved by the order dated 27.03.2000, the Appellant preferred an appeal being No.
The Appellant claimed to have supplied to Sumitomo Corporation the industrial and companymercial knowledge, information about market companyditions and Indian manufacturers of automobiles and also technical assistance as required by the Corporation.
The Appellant approached the High Court by filing T. Appeal No.
1603/D/2002.
272/01 02 before the Commissioner of Income Tax Appeals XXVI, New Delhi.
Sumitomo Corporation was interested in supplying dies for manufacturing of body parts to Indian automobile manufacturers and entered into a companytract with the Appellant under which the services of the Appellant herein were engaged by using his specialized companymercial and industrial knowledge about the Indian automobile industry.
The case of the Appellant was selected for scrutiny by the Income Tax Department, Delhi and in response to numberice under Section 143 2 of the IT Act, the Appellant along with others attended the assessment proceedings from time to time justifying the claim under Section 80 O of the IT Act.
The Assessing Officer, vide order dated 27.03.2000 under Section 143 3 of the IT Act assessed the total income at Rs.
Aggrieved by the judgment and order dated 13.12.2006, the Appellant has filed this appeal by way of special leave before this Court.
Heard Mr. Lakshmikumaran, learned companynsel for the Appellant and Mr. K. Radhakrishnan, learned senior companynsel for the Respondent and perused the records.
The Tribunal, vide order dated 10.10.2005, allowed the appeal filed by the Revenue.
43,25,960/ .
Being aggrieved by the order dated 20.02.2002, the Revenue went in appeal before the Tribunal.
1198 of 2006 challenging the order of the Tribunal dated 10.10.2005 which was dismissed on 13.12.2006 by a Division Bench of the High Court.
Sumitomo Corporation also agreed to pay remuneration at the rate of 5 of the companytractual amount between Sumitomo Corporation and its Indian customers on sales of its products so developed.
The services so rendered by the Appellant were in fact rendered and the payment was received for having rendered those services.
1198 of 2006 whereby the Division Bench of the High Court dismissed the appeal filed by the appellant herein against the order dated 10.10.2005 passed by the Income Tax Appellate Tribunal, Delhi Bench in short the Tribunal in ITA No.
K. Agrawal, J. The above appeal has been filed against the judgment and order dated 13.12.2006 passed by the High Court of Delhi in I.T. Appeal No.
The Appellate Authority, vide order dated 20.02.2002, partly allowed the appeal and held that the Appellant is entitled to deduction under Section 80 O of the IT Act.
Signature Not Verified Digitally signed by ASHA SUNDRIYAL Date 2018.04.24 174043 IST Reason Brief facts The Appellant herein filed return disclosing income of Rs.
