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Appeal to the High Court

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....he case involves a substantial question of law. (2) Notwithstanding the provisions of sub section (1), no appeal shall lie to High Court against an order passed by the Appellate Tribunal under section 83 if such order relates, among other things, to:- i) a matter where two or more States, or a State and Center, have a difference of views regarding the treatment of a transaction(s) being intra-S....

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....n of law is involved in any case, it shall formulate that question. (6) The appeal shall be heard only on the question so formulated, and the respondents shall, at the hearing of the appeal, be allowed to argue that the case does not involve such question: Provided that nothing in this sub-section shall be deemed to take away or abridge the power of the Court to hear, for reasons to be recorded,....

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.... any, of such Judges. (10) Where there is no such majority, the Judges shall state the point of law upon which they differ and the case shall, then, be heard upon that point only, by one or more of the other Judges of the High Court and such point shall be decided according to the opinion of the majority of the Judges who have heard the case including those who first heard it. (11) Where the Hig....