The Commr Of Income Tax vs M/S Samsung Electronics Co Ltd on 24 September, 2009
52. Even otherwise, the Revenue has not cited any direct case law of the
jurisdictional High Court of Bombay before us. In the case laws cited by the
Revenue of the Hom'le Karnataka High Court in the matter of CIT Vs.
Samsung Electronics Company Ltd." (supra) and CIT Vs. Synopsis
International Old Ltd. (supra) though a view in favour of the Revenue has
been taken, but, the Hon'ble Delhi High Court in the case of DIT Vs. Infrasoft
Ltd. (supra) which is a latter decision and has discussed the Samsung case
also has taken the view in favour of the assessee.