The Director Of Income Tax (It)-I v.

sbw *1* IN THE HIGH COURT OF JUDICATURE AT BOMBAYORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.431 OF 2012 The Director of Income Tax (IT)-I..Appellant-Versus-M/s. DHL Operations B. V.C/o PWC Pvt. Ltd. ..Respondent ........... Mr. Tejveer Singh for the Appellant.Mr. P. J. Pardiwalla, Senior Counsel, with Mr. Madhur Agarwal & Balasaheb Yewale i/b. Rajesh Shah & Co. for the Respondent. ........... CORAM: S.C. DHARMADHIKARIAND B.P. COLABAWALLA, JJ. DATE :- 17[th] JULY, 2014 P.C.: 1]Having heard Mr. Tejveer Singh, learned counsel, appearing in support of this appeal and Mr. Pardiwalla, learned Senior Counsel, appearing for the assessee, we are of the opinion that the order passed by the Tribunal on 21[st] September, 2011 in the assessee's appeal for the assessment year 2003-04 does not raise any substantial question of law. The Tribunal has assigned cogent and satisfactory reasons as to why the Assessing Officer could not have undertaken the exercise in the limited jurisdiction. Even otherwise, on merits as well, the Tribunal's view cannot 1/2 be said to be perverse. The Tribunal in the peculiar facts and considering the double taxation avoidance agreement rendered a finding following its own Special Bench decision. For all these reasons, we do not find that the appeal raises any substantial question of law. The appeal is, therefore, dismissed. No costs. (B.P.COLABAWALLA, J.) (S.C. DHARMADHIKARI, J.) wadhwa