2013 (5) TMI 72

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....DER:- 1. In this appeal by the revenue 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 transpor....

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....;  (d) Whether on the facts and in the circumstances 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....