2024 (3) TMI 1349

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....nt Varma And Hon'ble Mr. Justice Purushaindra Kumar For the Respondent : Mr. Rohan Khare and Ms. Priyam Bhatnagar, Advocates. For the Respondent : Mr. Rohan Khare and Ms. Priyam Bhatnagar, Advocates. ORDER 1. The Revenue has instituted the instant appeals and has proposed the following questions of law for our consideration:- "2.1 Whether on the facts and in the circumstan....

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....e of our order of 14 December 2022 and which is extracted hereinbelow:- "2. Issue notice. 2.1 Mr Deepak Chopra accepts notice on behalf of the respondent/assessee. 3. We may note, that it is Mr Chopra's contention, that apart from anything else, the issue which arises for consideration in the instant case, i.e., as to whether the revenue received on account of advert....

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....evenue has accepted the regime put in place by MAP in Assessment Years (AYs) 2007-2008 and 2008-2009. 6.1 Mr Chopra says, that the assessment orders, insofar as these assessment years were concerned, were passed under Section 143(3) of the Income Tax Act, 1961 [in short "Act"]. 7. Insofar as the above-captioned matters are concerned, we are told by learned counsel for the parties....

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....e Mutual Agreement Procedure having been adhered to by respective parties and consequent to the adjudication completed therein, the assessee having agreed to pay 10% of advertising and subscription revenue is not disputed. As would be manifest from a reading of paragraph nos. 4 to 6 of our order dated 14 December 2022, the aforesaid practice is also stated to have been accepted by the Revenue for ....