https://www.taxtmi.com/caselaws?id=12924 Section 104 of the Income-tax Act was considered in light of a notification relating to services rendered outside India. The Tribunal found that the design, technical know-how, and services were received and utilised in Cuba, and that the payment was attributable to that overseas utilisation; on that factual basis, the notification conditions were treated as satisfied and the disallowance and additional demands were regarded as unsustainable. The High Court characterised the controversy as one of factual appreciation rather than a debatable legal issue, and therefore held that no referable question of law arose from the Tribunal's order. The reference was declined and the Tribunal's view in favour of the assessee remained undisturbed. en-us Wed, 08 Aug 2001 00:00:00 +0530 Mon, 25 May 2009 10:53:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12924 Section 104 of the Income-tax Act was considered in light of a notification relating to services rendered outside India. The Tribunal found that the design, technical know-how, and services were received and utilised in Cuba, and that the payment was attributable to that overseas utilisation; on that factual basis, the notification conditions were treated as satisfied and the disallowance and additional demands were regarded as unsustainable. The High Court characterised the controversy as one of factual appreciation rather than a debatable legal issue, and therefore held that no referable question of law arose from the Tribunal's order. The reference was declined and the Tribunal's view in favour of the assessee remained undisturbed. Case-Laws Income Tax Wed, 08 Aug 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12924