2014 (10) TMI 858

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....NT This appeal is by the assessee challenging the order passed by the Tribunal. 2. The substantial questions of law that are raised in this appeal are, "i) On the facts and circumstances of the case whether the Appellate Tribunal is right in holding that the appellant is rendering 'technical services ' outside India in connection with the export of computer software? ii) On the facts a....

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....22 & 1130/Bang/2003 dated 7.4.2006 is not applicable to the appellant's case?" 3. Insofar as substantial questions of law 1, 2 and 4 are concerned, they are interconnected. This Court had an occassion to consider the substantial questions of law in the case of The Commissioner of Income Tax & another v/s. Motor Industries Co. Ltd. in I.T.A.No.776/2007 and connected matters decided on 13.6.2014,....