IN THE HIGH COURT OF DELHI AT NEW DELHI
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ITA 568/2010
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COMMISSIONER OF INCOME TAX ..... Appellant
Through : Ms Prem Lata Bansal
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versus
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TEI TECHNOLOGIES P.LTD. ..... Respondent
Through : None.
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CORAM:
HON'BLE MR. JUSTICE BADAR DURREZ AHMED
HON'BLE MR. JUSTICE V.K. JAIN
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O R D E R
13.05.2010
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CM 5234/2010
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Allowed, subject to just exceptions.
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ITA 568/2010
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This appeal is directed against the order dated 6.2.2009 passed by the
Income Tax Appellate Tribunal in respect of the assessment year 2003-2004 The
issue sought to be raised before us is whether the technical support fee
amounting to Rs 1,32,05,273/- paid by the assessee to Elentec Company Courier
and Tyco Investments Limited, Mauritius were in the nature of revenue or capital
expenditure. The Assessing Officer held the same to be of a capital nature.
However, the Commissioner of Income Tax(Appeals) relying upon the Tribunal?s
order in respect of the assessment year 2001-2002 held the same to be of revenue
nature. The Income Tax Appellate Tribunal, in turn, relied on its earlier order
in respect of the assessment year 2001-2002 and confirmed the view taken by the
Commissioner of Income Tax(Appeals).
The revenue preferred an appeal before this Court in respect of the
Tribunal?s order pertaining to the assessment year 2001-2002 and the said appeal
was numbered as ITA 909/2007. The same came up for hearing before this Court on
19.2.2008, when, placing reliance on the decision of the Supreme Court in Empire
Jute Co. Ltd. vs. Commissioner of Income Tax, [1980] 124 ITR 1, this Court
found that the Commissioner of Income Tax (Appeals) had returned concurrent
findings of fact and the same did not require any interference. This Court held
that no substantial question of law arose for its consideration.
Following the said decision dated 19.02.2008, in respect of the earlier
year, the present appeal is also dismissed.
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BADAR DURREZ AHMED,J
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V.K. JAIN, J
MAY 13, 2010/?sn?
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$ 3