2013 (5) TMI 72

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....e for the assessment year 2007-08, the following questions of law are raised for our consideration:-      (a) Whether on the facts and in the circumstances of the case the ITAT was justified in holding that the appellant is not entitled to the benefit of Article 8 of the DTAA in respect of freight income received on account of transportation of cargo on FVs from origin port to....

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....umstances of the case the ITAT was justified in holding that the appellant has an agency permanent establishment in India      (e) Whether on the facts and in the circumstances of the case the ITAT was justified in holding that the remuneration paid to the agent is not a relevant factor for taxing the profits and gains in india ? 2. Counsel for the parties states that in view....