End Of Picture Text -----<Br> v. Commissioner Of Income Tax Respondent Through Mr.r.d.jolly, Advocate

*IN THE HIGH COURT OF DELHI AT NEW DELHI 55. ^ : +ITA1198/2006B.L.PASSr .....AppellantThrough Mr.C.S.Aggarwal, SeniorAdvocate with Mr. Prakash Kumar,Advocate, versusCOMMISSIONER OF INCOME TAX RespondentThrough Mr.R.D.Jolly, Advocate. CORAM:HON'BLE MR. JUSTICE yiKRAlVIAJIT SENHON'BLE DR. JUSTICE S. MURALIDHARO R D E R%13.12.2006 Learned counsel for the appellant contends that thesubstantial question of law which arises in the presentappeal requires the consideration of the agreement enteredinto between the assessee and the Sumitomo Corporation.We have perused the various clauses of the agreement andthe correspondence relied upon by the appellant. We are inagreement with the view taken by the ITAT that thearrangement was in the nature of an agency which wouldnot attract the provisions of Section 80-O of the Income TaxAct. Dismissed. VIKRAMAjrr SEN, J Signature Not Verified S. MURALIDHAR, J