1. This appeal filed by the assessee is directed against the: order dated 22-10-2008 of the CIT(A)-XXXIII, Mumbai.

2. Facts of the case, in brief, are that the assessee, Goodlass Neroiae Paints Ltd., vide its application under section 195(2) of the act dated 11-2-2002 requested the Assessing Officer to issue certificate determining the sum chargeable to tax and tax to be deducted at source under the provisions of section 195 of the Income-tax Act, 1961 in respect of fee for computer software of US$ 43,000 to the non-resident M/s. IXOS Software Asia Pvt. Ltd., Singapore. The assessee vide its letter dated 11-2-2002 submitted its contention before the Assessing Officer as under:

1.All the aforesaid locations are connected to each other by an online real time accounting system. Everyday a huge volume of data is generated and stored on the main server situated at head office. This adversely affects the processing speed of the accounting system.

2.To overcome the above problem, we are planning to buy a software which will regularly transfer the data from main server to an auxiliary server in a compressed form and will retrieve the data in uncompressed form whenever required.

3.We, ther