2013 (11) TMI 1682

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.... N. K. Billaiya (Accountant Member) This appeal by the Revenue is directed against the order of the Ld. CIT(A)-11, Mumbai dt.19.8.2011 pertaining to A.Y. 2008-09. 2. The only grievance of the Revenue is that the Ld. CIT(A) erred in directing the AO to treat the assessee as eligible for the benefit of DTAA between India and UAE. 3. At the very outset, both the parties agreed that the iss....

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....rd the rival submissions and on careful perusal of the Tribunal order, it is observed that the following points are considered by the Tribunal in its order dated 30.11.2005. "As for the assessing officer's reliance on ruling given by the Authority for Advance Ruling in Cyril Eugene Pereiria's case (supra), we deem it necessary to reproduce the following extracts from the judgment of Hon&#....

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....ect to the applicant and the said transaction. It is, therefore, obvious that, apart from whatever its persuasive value, it would be of no help to us. Having perused the order of the Advance Ruling Authority, we are not persuaded." Being the facts and circumstances are identical to that of the above case, respectfully following the Tribunal orders, we are of the considered opinio....