COMMISSIONER OF INCOME TAX II Vs. SOFTWARE CONSULTANTS

JUDGEMENT

(1.) THIS appeal under Section 260A of the Income Tax Act, 1961 (Act, for short) impugns the order dated 26th September, 2008 passed by the Income Tax Appellate Tribunal (tribunal, for short) in ITA No. 2554/D/2004 in the case of Software Consultants (India) Private Limited. The appeal pertains to the assessment year 1993-94.

(2.) BY order dated 17th October, 2011, the following substantial question of law was framed:

(3.) IN this assessment order dated 28th March, 2002, the Assesssing Officer had also noted as under:-