Appellant) respectfully craves leave to p refer an appeal under Section
253 of the Income-tax Act, 1961 ('Act') against the order passed ... absence of enactment through appropriate legislation in
accordance with Article 253 of the Constitution, courts do not possess any power to
pronounce on the power
treaty, we have already
held in Ericsson (supra) that a copyrighted article does
not fall within the purview of Royalty. Therefore, we
decide question ... absence of
enactment through appropriate legislation in accordance
with Article 253 of the Constitution, courts do not
possess any power to pronounce on the power
absence of enactment through
appropriate legislation in accordance with Article 253 of the
Constitution, courts do not possess any power to pronounce on
the power
Revenue, on the other hand, on a combined reading of
Article 253 of the Constitution of India and section 90 of the Act,
argued that ... exclusive executive power to enter into
international treaties and conventions under Article 73 [ read with
corresponding Entries - Nos. 10, 13 and 14 of List
Revenue, on the other hand, on a combined reading of Article
253 of the Constitution of India and section 90 of the Act, argued that ... exclusive executive power to enter into international
treaties and conventions under Article 73 [ read with corresponding
Entries - Nos. 10, 13 and 14 of List
treaty, we have already held in Ericsson (supra) that a copyrighted
article does not fall within the purview of Royalty. Therefore, we
decide question ... absence of enactment
through appropriate legislation in accordance with Article 253 of the
Constitution, courts do not possess any power to pronounce on the
power
absence of enactment through appropriate legislation in accordance with
Article 253 of the Constitution, courts do not possess any power to
pronounce on the power
absence of
enactment through appropriate legislation in accordance with Article 253 of
the Constitution, courts do not possess any power to pronounce on the power
Apl Co. Pte Ltd., Mumbai vs Adit (Int'L Taxation)-1(1), Mumbai on
Mishapar Investments Ltd. vs Ito on 23 February, 2006
Equivalent citations: [2006]8SOT532(MUM)
ORDER
