2001 (8) TMI 41

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....d at the instance of Revenue under section 256(2) by the Income tax Appellate Tribunal (in short "the Tribunal") for the opinion of this court. "Whether, on the facts and in the circumstances of the case and on a proper construction of the notification No. S.0. 3210, dated August 8, 1969, issued by the Central Government, the Tribunal was right in holding that the provisions of section 104 of the....

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....d from the order of the Tribunal that it has taken note of certain factual aspects and has recorded the following conclusions which are essentially factual in nature. "The design, technical know-how and services which were rendered to the foreign company were all received and utilised in Cuba, i.e., outside India. The expression in the notification dated June 6, 1967, 'services rendered out side ....