\ 0\ *IN THE HIGH COURT OF DELHI AT NEW DELHI 55. ^ : + ITA1198/2006 B.L.PASSr .....Appellant Through Mr.C.S.Aggarwal, Senior Advocate with Mr. Prakash Kumar, Advocate, versus COMMISSIONER OF INCOME TAX Respondent Through Mr.R.D.Jolly, Advocate. CORAM: HON'BLE MR. JUSTICE yiKRAlVIAJIT SEN HON'BLE DR. JUSTICE S. MURALIDHAR O R D E R % 13.12.2006 Learned counsel for the appellant contends that the substantial question of law which arises in the present appeal requires the consideration of the agreement entered into between the assessee and the Sumitomo Corporation. We have perused the various clauses of the agreement and the correspondence relied upon by the appellant. We are in agreement with the view taken by the ITAT that the arrangement was in the nature of an agency which would not attract the provisions of Section 80-O of the Income Tax Act. Dismissed. VIKRAMAjrr SEN, J S. MURALIDHAR, J DECEMBER 13, 2006 dn Digitally Signed By:AMULYA Signing Date:19.02.2024 16:39 Certify that the digital file and physical file have been compared and the digital data is as per the physical file and no page is missing. Signature Not Verified