(1.) WE have heard Mrs. Mauna M. Bhatt, learned counsel for the Revenue in this Tax Appeal.
(2.) THIS appeal has been filed by proposing the following substantial question of law:
(3.) WE are in agreement with the view taken by the Tribunal as it is not the case of the Department that the assessee has filed no evidence with regard to payment made to the non-resident agents/parties and in view of the CBDT's Circulars of the year 1996 and 2000, no tax was required to be paid nor any TDS was required to be deducted. For the aforesaid reasons, we do not find that any substantial question of law arises for consideration. This Tax Appeal is accordingly dismissed.