Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent
132 & 165/PAN/2016 for A.Ys. 2008-09 & 2011-12 order dated 09/04/2018 wherein the Tribunal has observed and held as follows:- “16. We heard the rival contentions on this issue and perused the record. Since Hon'ble Supreme Court has held in the case of Kesoram Industries Ltd. & Ors. (supra) that royalty is not tax and since Hon'ble Gujarat High