2004 (1) TMI 25

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Income-tax (Appeals) as well as the Income-tax Appellate Tribunal, Delhi Bench "B", New Delhi, held against the Revenue and in favour of the assessee. The Revenue has preferred this appeal which pertains to the third instalment of a lump sum payment for technical services received by the assessee, a German company. The Assessing Officer had treated this payment as royalty and subject to tax. The ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ssessment year 1994-95 was decided by the Income-tax Appellate Tribunal on September 17, 2002. Thus, for a pretty long period, the decision was accepted by the Revenue. Consistency is required to be maintained by the Revenue. The Commissioner of Income-tax (Appeals), in the present case has merely followed the earlier order in respect of the assessment year 1990-91. The same has been done by the T....