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The Bombay High Court, with Justices K. R. Shriram and Dr. Neela Gokhale presiding, dismissed the appeal. Counsel for both parties acknowledged that the specific question of law is addressed by the Supreme Court's decision in Principal Commissioner of Income Tax, Vadodara vs. Petrofils Cooperative Ltd. (2021) 130 taxmann.com 191 (SC), which was decided in favor of the assessee. Consequently, the Court held that "no substantial question of law arise," leading to the dismissal of the appeal.
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