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Judgment
Ravi Malimath, J
Five substantial questions of law have been raised for consideration in this appeal. Shri Hari Mohan Bhatia, learned counsel for the appellant and
Shri P.R. Mullick, learned counsel for the respondent, submit that the questions of law that arise for consideration in this appeal have since been
decided by the order of the Full Bench of this Court in Director of Income Tax International Taxation and Ors. Vs. Schlumberger Asia Services
Ltd. and Ors. reported in 414 ITR Page 1, in terms whereof, the questions of law have been answered against the revenue and in favour of the
assessee.
In view of the submission made by the learned counsels, the questions of law that arise in this appeal are also answered in favour of the assesse
and against the revenue by following the order of the Full Bench of this Court in Director of Income Tax International Taxation and Ors. Vs.
Schlumberger Asia Services Ltd. and Ors. reported in 414 ITR Page 1.
The income tax appeal is accordingly dismissed.