Karnataka High Court decision in CIT (Intl. Taxation) v. Samsung Electronic Co. Ltd., reported in 185 TAXMAN 313 is not based on current law in the light of the new procedure streamlined by the Government of India from 18-11-1997. I have posted an Article in Tax Titans on this topic which was Published in TAXMANN'S CORPORATE PROFESSIONALS TODAY- VOLUME 17 (Issue 4) Page No.315 under the caption "Karnataka High Court decision in CIT (Intl. Taxation) v. Samsung Electronic Co. Ltd., reported in 185 TAXMAN 313 is not based on current law".