2012 (12) TMI 737

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....iwala, Senior Advocate with Mr.Sameer Chitnis i/by Crawford Bayley & Companyt for the respondent.     P.C. : 1. This appeal is filed by the Revenue raising following questions of law. i) Whether on the facts and in the circumstances of the case the Tribunal was right in law in holding that the Royalty and fees for technical services should be taxed on receipt basis without a....

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....August 1985 held that the assessment of royalty or any fees for technical services should be made in the year in which the amounts are received and not otherwise. Counsel for the Revenue relied upon the Special Bench decision of the Tribunal in the assessee's own case, which in our opinion, has no relevance to the facts of the present case, as it relates to the period prior to the issuance of Noti....