COMMISSIONER OF INCOME TAX Vs. PROMAIN LTD

JUDGEMENT

(1.) HAVING heard counsel for the parties, we frame the following two substantial questions of law :

(2.) WE have heard counsel for the parties and proceed to dictate our decision on the aforesaid questions.

(3.) IN paras 10 to 14 of the impugned order, the Tribunal has recorded and observed as under :