2019 (8) TMI 1856

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....cha For the Respondent : Mr.F.V.Irani i/b Mr.Atul K.Jasani ORDER P.C.: Heard. 2. Both these Appeals under section 260 A of the Income Tax Act, 1961 (the 'Act') challenge a common order dated 31 March 2016 passed by the Income Tax Appellate Tribunal, Mumbai ('Tribunal'). The Appeals relate to Assessment Years 2008-09 and 2009-10. Thus the two Appeals. 3. Ms.Bharucha, learned couns....

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....s question as proposed therein on the grounds that the same in the facts of the case was academic in nature. This for the reason what was being paid by the Indian entity to its Singapore branch was only in the nature of reimbursement of expenses. This finding of fact was not challenged in the Revenue's appeal for Assessment Year 2006-07 or in these appeals for Assessment Year 2008-09 and 2009-10. ....