2014 (3) TMI 815

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....earned counsel for the parties to the lis. 2. Leave granted. 3. The following questions of law were raised by the appellant before the High Court: "i) Whether on the facts and in the circumstances of the case and in law, the Tribunal erred in holding that the procurement fees of Rs.5.30 crores payable of M/s Tech Source Corporation is not liable to be taxed in India under Section 9(1)(i) ....