2015 (1) TMI 1418

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....t. P.C.: This Appeal challenges the order passed by the Income Tax Appellate Tribunal, Bench at Mumbai, in Income Tax Appeal No.2781 of 2011. The assessment year in question is 200304. 2] Mr. Suresh Kumar, learned counsel, submits that this Appeal raises the substantial questions of law and particularly as formulated in the memo of Appeal by the Revenue. He would submit that the Tribunal ....

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....nches outside India generated income and which was subjected to the law pertaining to tax on income abroad. Once the factual position is not disputed by the Revenue, then, the benefit of the Double Taxation Avoidance Agreement has been rightly extended. He relies upon the findings in the Tribunal's order impugned in this Appeal and particularly para 28 thereof. 4] With the assistance of Mr.....