SAP LABS INDIA PRIVATE LIMITED Vs. THE INCOME

JUDGEMENT

(1.) This appeal has been filed by the Assessee - SAP Labs India Private Limited raising purported substantial questions of law arising from the Order of the learned Income Tax Appellate Tribunal Bangalore Bench "A", Annexure A dated 30/08/2010 in ITA No.398/Bang/2008 for AY 2003-04.

(2.) We have heard the learned counsel for the Respondent - Revenue, Mr, E.I. Sanmathi.

(3.) The appeal was admitted by the Co-ordinate Bench of this Court on 30-11-2011 with the following two Substantial Questions of law:-