2019 (5) TMI 1393

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....ir Bhatia, Senior Standing Counsel for Revenue.   Respondent Through: Mr. Rahul Chaudhary, Advocate.   O R D E R 1. These are appeals by the Revenue against the common order dated 13th September 2017 passed by Income Tax Appellate Tribunal ('ITAT') in ITA No. 4050 and 4051/Del/2014 for Assessment Years 2010-11 and 2011-12. 2. The common question sought to be urged by the Reve....

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....sharing percentage had been reduced from 10% to 8%. Although, the AO did not accept the explanation offered by the Assessee, it has been found to be acceptable both by Commissioner of Income Tax - CIT (A) in the order dated 22nd April 2014 and the ITAT in the impugned order. 4. The impugned order in fact discusses the relevant clauses of the agreement and concludes that the explanation offered ....