2022 (11) TMI 631

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....s. Justice Manmeet Pritam Singh Arora For the Appellant : Mr. Ruchir Bhatia, Senior Standing Counsel for Revenue. For the Respondent : Mr. Divyanshu Agrawal, Ms. Ritika Chawla & Mr. Vaibhav Niti, Advocates. JUDGMENT MANMOHAN, J (Oral): CM APPL. 47203/2022 (for exemption) in ITA 435/2022 Exemption allowed, subject to all just exceptions. Accordingly, the present application is disposed ....

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....2(4) (a) of the Indo- US DTAA. 3. He states that the ITAT has allowed the appeals of the Assessees following the judgement of this Court in Director of Income Tax v. Sheraton International Inc (2009) 178 taxman 84 (Del). He, however, states that the said decision of this Court has not been accepted by the Revenue and an appeal has been preferred against the same, which is pending adjudication bef....