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
127 (Del).
17. The relevant clauses in the LA have been extracted hereinabove.
Although a plain reading of Clause 2 of the LA might show that the
payment by the Assessee to the AI for the operation of the executive
lounge at IGI Airport is split into two distinct parts viz., , royalty and the
fees for the space
