SHAAN MARINE SERVICES PRIVATE LIMITED Vs. DY. DIT

JUDGEMENT

(1.) THIS appeal has been filed by the assessee against the order of Commissioner of Income Tax (Appeal) -IT/TP [in short CIT(A)] Pune, dated 06.09.2013 for A.Y. 2012 -13 on the following grounds.

(2.) THE Ld. Commissioner of Income tax Appeals has erred in confirming the contention of the AO that the Income has accrued in India in the hands of the appellant as an agent although the same does not accrue or arise in India in view of applicable law and facts of the case.

(3.) THE Ld. Commissioner of Income tax Appeals has erred in law and in facts in not following the terms of the tax treaty entered between India and other country (Cyprus).