2015 (2) TMI 910

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.... CM No.2563/2015  Exemption is allowed subject to all just exceptions. The application is disposed of. CM No.2564/2015 For the reasons stated in the application the delay in re-filing the appeal is condoned. The application is disposed of. ITA 93/2015 1. The Revenue is aggrieved by the order dated 25.11.2011 of the Income Tax Appellate Tribunal (ITAT) in ITA Nos.1682, ....

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.... (A), who followed the Division Bench ruling of this Court in Commissioner of Income Tax vs. NHK Japan Broadcasting Corporation (2008) 305 ITR 137 (Del) and CIT vs. Hutchison Essar Telecome Ltd. (2010) 323 ITR 230 (Delhi) concludes the issue. In NHK Japan (Supra) the Court had said that even though no specific period of limitation was prescribed for action under Section 201, the Income Tax Authori....

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....r any part of the tax from a person resident in India, at any time after the expiry of seven years from the end of the financial year in which payment is made or credit is given" 4. We have considered the arguments of the Revenue and are of the opinion that the substantial time as extended in the previous judgment of this Court in Commissioner of Income Tax (TDS)-I vs. C.J.International Hotels ....