2020 (8) TMI 475

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.... Singh Dhanik, J. Shri Hari Mohan Bhatia, learned counsel for the petitioner Shri Pulak Raj Mullick, learned counsel for the respondent ORDER Hon'ble Ravi Malimath, ACJ. (Oral) The appellant has raised the following substantial questions of law: "(1) Whether on the facts and circumstances of the case, the Hon'ble ITAT has erred in holding that the amount received by....

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....roject undertaken by the recipient" in terms of decisions of Hon'ble Delhi High Court in DIT vs. Rio Tinto Technical Services [2012-TII-01-HC-Del-INTL]. (3) Whether on the facts and in the circumstances of the case the Hon'ble ITAT has erred in his interpretation of the legislative intent behind the scheme of taxation envisaged in 9 (1)(vi) read with sections 44DA and 44BB, ignori....

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....xation of income in the nature of Royalties' and FTS and if a special provisions is made respecting a certain matter that matter us excluded from the general provision under the rule of "Generalities speciallibus non derogant" (6) Whether on the facts and circumstances of the case, the Hon'ble ITAT has erred in not appreciating the fact that proviso to section 44DA brought by the ....