2012 (5) TMI 604

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....nbsp;  ORDER  We have heard the learned counsel for the parties. We frame the following substantial question of law:-  1. Whether the Income Tax Appellate Tribunal is right in holding that Section 40(ia) of the Income Tax Act, 1961 is not applicable to testing fee of Rs. 14,71,095/- paid to M/s. CSA International, Chicago as there was no failure on the part of the responden....