WIPRO GE HEALTHCARE PRIVATE LIMITED GE MEDICAL SYSTEMS INDIA PRIVATE LIMITED 122 Vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 11(3)

JUDGEMENT

(1.) These Appeals are filed by the Assessee purportedly raising substantial questions of law arising from the Order of the Income Tax Appellate Tribunal, Bangalore Bench 'A', Bangalore in IT[TP]A Nos.332, 333 and 337/Bang/2011 dated 30.06.2015, relating to the Assessment Years 2004-05 and 2005-06 which are quoted below for ready reference.

(2.) The learned Tribunal, after discussing the rival contentions of both the Appellant-Assessee and Respondent-Revenue, has returned findings as under:

(3.) The controversy involved herein is no more res integra in view of the decision of this Court in I.T.A. Nos.536/2015 c/w 537/2015 dated 25.06.2018 [Prl. Commissioner of Income Tax and Anr. v. M/s.Softbrands India Pvt. Ltd.] wherein it has been observed that unless the finding of the Tribunal is found ex facie perverse, the Appeal under section 260-A of the Act, is maintainable. The relevant portion of the Judgment is quoted below for ready reference: