2011 (3) TMI 1819

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....Kumar Mahajan, CIT DR For the Respondent : Shri Farookh V. Irani, Advocate ORDER PER BENCH: 1. All these four appeals by the revenue and four cross objections of the assessee are directed against the combined order of Ld. CIT(A)- XXIX, New Delhi dated 11.02.2010 for the assessment years 1999-2000 to 2002-03. For the sake of convenience, all these appeals and cross objections are being ....

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....re and data processing fee. It is submitted that in assessment year 1995-96 to 1998-99, similar issue in assessee's own case was decided by the tribunal and it was held that only 15% of the revenue generated for the booking made within India can be considered as attributable to the PE in India and hence only 15% of the revenue generated from the booking made within India is taxable in India. It wa....

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....ed by the tribunal against the assessee in assessment year 1995-96 to 1998-9. He submitted a copy of tribunal decision in assessee's own case for these assessment years 1995-96 to 1998-99 in I.T.A. Nos. 1733/D/2001, 2473-2475/D/2000 and 820-823/D/2005 and C.O. No.47 to 54/D/2006 dated 30.11.2007. It is also submitted that against this tribunal order, both the assessee and revenue were in appeal be....

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....and 17471-72/2008. He submitted a copy of both these judgments of Hon'ble High Court of Delhi rendered in the assessee's appeals as well as revenue's appeals. Ld. DR also agreed that these issues are covered as per these judgements. 5. We have considred the above factual and legal position and we find that only one issue is involved in the appeals of the revenue that whether the Ld. CIT(A),....