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of Revision u/s 264 - payment of tax on FTS under the DTAA at wrong rate (20% instead 10%) - it is not even denied by the Department that the Petitioner committed a mistake and should have paid tax at 10% - extra 10% paid by the Petitioner was of its own volition, it was indeed prejudicial to the Assessee - all the ingredients of Section 264 stand attracted hence permissible
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