2013 (5) TMI 1006

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....the counsel for the parties. The revenue has proposed the following questions as substantial questions of law:- 1. Whether the Income Tax Appellate Tribunal was correct in law and on facts in deleting the addition on account of technical know-how of ₹ 61,20,05,000/- and royalty of ₹ 81,71,60,464/- paid by the assessee to Honda Motor Co. Ltd. 2. Whether the Income Tax Appellate ....

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....d, that issue stands covered in favour of the respondent / assessee by virtue of the decision of the Supreme Court in the case of CIT v. Samtel Color Ltd. decided in Civil Appeal No. 6448/2012 on 12.09.2012. Consequently that question does not arise any further. As regards proposed question No. 3, the issue is also covered in favour of the assessee by virtue of the Supreme Court decision in Roto....