2020 (10) TMI 462

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....ANT ORDER ( PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA) 1. This Tax Appeal under Section 260A of the Income Tax Act, 1961 (for short "the Act, 1961") is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Ahmedabad Bench "C", Ahmedabad in ITA No. 370/Ahd/2018 for A.Y. 2013-14. 2. The Revenue has proposed the following two questi....

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....ame assessee with respect to the earlier Assessment Year, the Tax Appeal No. 265 of 2019 preferred by the Revenue came to be dismissed by this Court vide order dated 09.07.2019. Ms. Bhatt pointed out that the very same questions were proposed in the Tax Appeal No. 265 of 2019 as proposed in the present appeal. The Tax Appeal No. 265 of 2019 came to be dismissed in the following terms:- ....

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.... on account of the disallowance of Rs. 2,93,56,350/ under section40(a)(ia)of the Act for non deduction of the tax of the source of commission payable to the foreign agent. The questions of law as proposed by the revenue has no longer integreta in view of the decision of this Court in the case PR CIT Vs. MGM Exports rendered in Tax Appeal No.309 of2018, dated 11/04/2018.4.The ratio of the decision ....