1998 (6) TMI 567

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....T DR.B.P.Saraf,J.-By this reference under s. 256(1) of the IT Act, 1961 (the 'Act'), the Tribunal has referred the following two questions of law to this Court at the instance of the assessee for opinion. "(i) Whether the amount of Rs. 9,28,328 representing fee for use of manufacturing know-how and for necessary training of the applicant's personnel outside India, paid to Ciba Ge....