2023 (1) TMI 869

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....r. Standing Counsel for the Revenue. For the Respondent : Mr. S.S. Tomar with Mr. Vishal Kalra, Advocates. J U D G M E N T MANMOHAN, J (Oral): 1. Present income tax appeals have been filed challenging the order dated 13th December, 2021 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No. 4946/Del./2017 for the Assessment Year 2014-15 and the order dated 11th October, 2021 in ITA No....

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....l within the meaning of word process, as appearing in Clauses (i), (ii) & (ii) of explanation 2 of Section 9(l)(vi) and Article 12(3) of the DTAA between India and USA. 3. Admittedly, the questions of law urged in the present appeal are covered by the decision of this Court in assessee's own case in ITA 900/2019 pertaining to the Assessment Year 2013-14, wherein this Court dismissed an appeal of ....