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| The Tax Publishers2020 TaxPub(DT) 4553 (Karn-HC) INCOME TAX ACT, 1961
Section 92C
Competent authority of USA and India have reached mutual agreement and on the basis of the aforesaid agreement, AO had passed an order giving effect to mutual agreement procedure. It was also pointed out that in view of the order passed by AO, the substantial questions of law involved in this appeal have been rendered academic. As revenue submitted that appeal might be disposed of with liberty to the revenue to revive the same.
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Appeal (High Court) - Substential question of law - Tax authori ties reached mutual agreement -
Issue arose for consideration whether Tribunal were right in law in adopting turnover filter of Rs. 200 crore when turnover was not a relevant filter in software industry and when the size of the turnover and profit margins were not linked in the software industry unlike capital intensive companies.Held: Assessee submitted that competent authority of USA and India have reached mutual agreement and on the basis of the aforesaid agreement, AO had passed an order giving effect to mutual agreement procedure. It was also pointed out that in view of the order passed by AO, substantial questions of law involved in this appeal have been rendered academic. As revenue submitted that appeal might be disposed of with liberty to the revenue to revive the same.
REFERRED :
FAVOUR : Directions issued.
A.Y. : 2006-07
IN THE KARNATAKA HIGH COURT
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