(1.) Heard Sri Manish Mishra, Advocate, for appellant and perused the record.
(2.) This appeal under Sec. 260-A of Income Tax Act, 1961 (hereinafter referred to as "Act, 1961") arising from judgment and order dated 28.02005 passed by Income Tax Appellate Tribunal, Lucknow Bench, Lucknow (hereinafter referred to as "Tribunal") in Income Tax Appeal No. 596/Alld/95 and Income Tax Appeal No. 450/Alld/95 Tribunal was admitted on following two substantial questions of law:
(3.) In the present case, from the facts, as emerged from record, it is clear that "technical know-how" remained property of Foreign Company and Assessee has only right to use the same on payment of royalty to the said Company.