(1.) By this appeal, the appellant - Revenue has challenged the order passed by the Income Tax Appellate Tribunal, Mumbai, dtd. 25/5/2016. The present appeal pertains to the Assessment Year 2008-09.
(2.) The appellant has placed the following questions of law for our consideration which according to the appellant are substantial questions of law :-
(3.) The respondent assessee - Sygenta Bioscience Pvt. Ltd. carries out research and technical services to the Syngenta Group which is in business of HYV Seeds and Crop Protection Sciences internationally.