Dismissing the petition the Court held that it was not clear why two agreements were signed with the same parties and the payments were made only to the same Indian company. The valuation in the agreement was not clearly explained by the assessee. Though it was submitted that the Indian company had paid a sum of Rs.15 crores to the assessee, it was found from the annual report filed for the financial year ending on March 31, 2005 that only a sum of Rs. 1,50,000 was paid under the second agreement. Further, it was also not clear whether the tax was paid in the returns filed for the years 2004-05 and 2005-06 and there were also disputed questions of fact involved as to whether the tax had been paid by the-assessee during the succeeding Assessment years. Writ was dismissed. (AY. 2003-04) (SJ)