COMMNR.INCOME TAX vs. PIYUSH KU GUPTA
ITA/123/2005HC Orissa02 Feb 2022
Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK
Section 194Section 201Section 260ASection 271C
Income Tax (2007) 8 SCC
463.
15. In reply, Mr. Ajay Vohra, learned Senior counsel for the Assessee
referred to the decision in Japan Airlines Co. Limited v. CIT (2013)
377 ITR 372 (SC) to draw a distinction between the payment of royalty
which was for the right to operate the executive lounge, and which
amount was quoted
