2022 (10) TMI 1056

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....ent: Mr.Zoheb Hossain, Sr.Standing Counsel for the Revenue with Mr.Vipul Agrawal and Mr.Parth Semwal, Advocates. JUDGMENT MANMOHAN, J (Oral): C.M.No.42494/2022 Exemption allowed, subject to all just exceptions. Accordingly, the application stands disposed of. ITA No.370/2022 1. Present income tax appeal has been filed challenging the order dated 28th February, 2022 passed by the Income....

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....n accepted by the ITAT. 5. Upon a perusal of the paper book, this Court finds that all the three authorities below have given concurrent findings of fact that the Appellant had failed to furnish evidence to demonstrate that administrative services were actually rendered by the AE and the assessee had received such services. In fact, the ITAT has noted in the impugned order "....On a specific quer....