(M.R. Shah and C.T. Ravikumar, JJ.)
Director of Income Tax (International Taxation) Mumbai ________________________________________________ Appellant;
v.
Krupp Udhe GMBH _______________________________ Respondent.
Civil Appeal No. 2067 of 2012, decided on May 10, 2023
The Order of the court was delivered by
Order
1. The present Appeal is confined to only one question, namely, “whether when income is taxed on gross basis, non inclusion of charges towards reimbursement of expenses would be in violation of law as it would tantamount to taxation of income partly on net basis?”
2. It is reported that the tax effect on the aforesaid question would be Rs. 39,00,000/- (approx.), which will be below the monetary limit of Rs. 2 Crores to prefer an Appeal before this Court.
3. In that view of the matter, the present Appeal stands dismissed/disposed of on the ground of low tax effect only.
4. However, the question of law is left open.
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