Dismissing the appeal of the revenue the Court held that, Tribunal is justified in holding that addition cannot be made in respect of which no services were rendered. ( AY. 2004-05, 2005 -06)
PCIT v. Tulip Hospitality Service Ltd. (2019) 261 Taxman 16/( 2019) 411 ITR 595 (Bom.)(HC)
S. 28(i) : Business income–Royalty-Addition cannot be made in respect of which no services were rendered.