2023 (11) TMI 1198

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....v. Mrs. Geetanjali Mohan, Adv. Mr. Vaibhav Kulkarni, Adv. Mr. Udit Naresh, Adv. For the Respondent : Mr. Balbir Singh, A.S.G. Mr. Raj Bahadur Yadav, AOR Mr. Arijit Prasad, Sr. Adv. Mr. H R Rao, Adv. Mr. Vivek Narayan Sharma, Adv. Mrs. Deepabali Dutta, Adv. Mr. Rupesh Kumar, Adv. Mr. Shashank Bajpai, Adv. ORDER UPON hearing the counsel the Court made the following. Having heard learned ....

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....sessee(s) sought for rectification under Section 154 of the Act seeking a lesser rate of taxation to be imposed under the DTAA regime if the assessee(s) was not seeking to be taxed under the said regime. In response to the query of this Court, learned counsel for the assessee(s) submitted that although such an application seeking rectification was made nevertheless the assessee(s) was being tax....