2015 (5) TMI 1198

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....pondent by:- Sh.Judy James, Standing Counsel, D.R. ORDER J.Sudhakar Reddy, Both these appeals are filed by the assessee and are directed against separate orders of the Assessing Officer (A.O.) passed u/s 143(3) r.w.s. 144C of the Income Tax Act, 1961 (the 'Act') on 21.7.2010 pertaining to the Assessment Year ('A.Y.') 2006-07 and on 27.10.2011 for the A.Y. 2007-08. As the issues arising in....

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.... risk insulated basis in carrying out this activity. In respect of the profits earned by it from the provision of the above services, the assessee is entitled to a tax holiday u/s 10A of the Act and makes the necessary statutory filings with the Software Technology Park of India (STPI). During the relevant financial year, the assessee undertook the following international transactions with t....

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....bjections before the Dispute Resolution Panel (D.R.P.). Thereafter the D.R.P. passed its order u/s 144C(5) of the Act. Thereafter the A.O. passed order u/s 143(3) read with section 144C of the Income Tax Act, 1961 (the 'Act') for both the A.Ys. Aggrieved the assessee is in appeal before us. 4. We have heard Shri Kanchan Kaushal, CA and Shri Rohit Tiwari, CA along with Shri Anubhav Rastogi, CA, ....