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of Initiation of proceedings u/s 201(1) - period of limitation - It would be interesting to note that on the ground that the two foreign companies had filed applications before the AAR as to taxability of such transactions, petitioner had filed an application before DCIT to keep the proceedings u/s 201 in abeyance. Such an action of the petitioner would run counter to its very contention that the proceedings concluded by respondent No. 1 was beyond limitation. - Order u/s 201(1) sustained - HC
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