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    <description>The appeal was dismissed as no substantial question of law was found to arise, and the Tribunal&#039;s decision was upheld based on the factual findings and legal analysis presented. The delay of 210 days in filing the appeal was condoned. The disallowance under Section 40(a)(i) of the Income Tax Act was upheld, emphasizing the lack of business connection in India for the foreign companies involved. Consistency in decisions was highlighted regarding the application of the decision in the assessee&#039;s own case for a previous assessment year, leading to the Tribunal&#039;s decision being upheld despite arguments for distinctness of each assessment year.</description>
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      <description>The appeal was dismissed as no substantial question of law was found to arise, and the Tribunal&#039;s decision was upheld based on the factual findings and legal analysis presented. The delay of 210 days in filing the appeal was condoned. The disallowance under Section 40(a)(i) of the Income Tax Act was upheld, emphasizing the lack of business connection in India for the foreign companies involved. Consistency in decisions was highlighted regarding the application of the decision in the assessee&#039;s own case for a previous assessment year, leading to the Tribunal&#039;s decision being upheld despite arguments for distinctness of each assessment year.</description>
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