Sanjiv Khanna, J. - (1.) These appeals filed by the Revenue under Section 260A of the Income Tax Act, 1961 ("the Act" for short) impugn the order dated 31.05.2016 of the Income Tax Appellate Tribunal ("Tribunal" for short) in the case of Montage Enterprises Pvt. Ltd. ("respondent-assessee" for short). The appeals pertain to the Assessment Years 2005- 06 and 2006-07.
(2.) The appeals were admitted for hearing vide order dated 06.11.2017 on the following substantial questions of law:- "1. Whether assessee was right in reallocating expenditure/income on account of royalty from Jammu Unit to Corporate Division? 2. If the answer to the above is in the affirmative in favour of the Revenue, the further question which arises is whether the Assessee was entitled to deduction under Section 80-IB of the Income Tax Act, 1961 in respect of sub-licence fee (ITA 892/2016 &894/2016)?"
(3.) The respondent-assessee is part of the M/s Flex Group of companies and was engaged in the business of manufacturing, trading and sale of flexible packaging material.;