2018 (11) TMI 1697

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....lant : Mr. Vikas Srivastava, Adv. For the Respondent : Mr. Asheesh Jain, Sr. Standing Counsel, IT Department with Mr. Sanjay Kumar, Adv. ORDER Having heard the counsel for the parties, we are inclined to frame the following substantial question of law: "Whether Income Tax Appellate Tribunal was right in holding that Royalty and Sales Commission paid were separate and independent internationa....