2013 (6) TMI 188

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.... 1. By this Petition, the Petitioner seeks a review of the order dated 20th November, 2012 passed by this Court. By the order dated 20th November, 2012 DIT (IT) v. Deutsche Bank A.G. [IT Appeal No. 233 of 2011, dated 20-11-2012], this Court did not entertain the Revenue's Appeal for the Assessment Year 1994-95. This was in view of the fact that the Tribunal by order dated 28th January, 2010 whil....

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....uld be recalled. 3. In its order dated 28th January, 2010, the Tribunal has referred to the Agreement for the Double Taxation Avoidance Agreement (DTAA) Treaty entered into between Federal Republic of Germany and India on 28th June, 1984. The aforesaid DTAA inter alia, provided that deduction in respect of head office expenses would not be less than what is allowable under the Indian Income Tax....