2023 (12) TMI 772

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....TICE RAJIV SHAKDHER AND HON'BLE MR. JUSTICE GIRISH KATHPALIA For the Appellant Through: Mr Ruchir Bhatia, Sr Standing Counsel. For the Respondent Through: None. RAJIV SHAKDHER, J.: (ORAL) CM APPL. 63516/2023 in ITA 718/2023 CM APPL. 63597/2023 in ITA 722/2023 CM APPL. 63606/2023 in ITA 723/2023 CM APPL. 63622/2023 in ITA 724/2023 CM APPL. 63653/2023 in ITA 728/2023 CM APPL. 63....

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....g the appeal] CM APPL. 63654/2023 in ITA 728/2023 [Application filed on behalf of the appellant seeking condonation of delay of 460 days in re-filing the appeal] CM APPL. 63713/2023 in ITA 731/2023 [Application filed on behalf of the appellant seeking condonation of delay of 460 days in re-filing the appeal] 2. These are applications filed by the appellant/revenue seeking condonation of dela....

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....ia, learned senior standing counsel, who appears on behalf of the appellant/revenue, fairly concedes that insofar as the merits of the case are concerned the decision of the Supreme Court rendered in the case of the group entity of respondent/assessee holds the field. 8.1 Mr Bhatia, in this behalf, has drawn our attention to the following order passed by the Supreme Court in the case of Commissio....

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....y the appellant/revenue before the Tribunal was whether the view taken by CIT(A) that 15 percent of the profits earned from Indian operations could be attributed to the respondent/assessee was sustainable. The coordinate bench in AY 2006-07 while dealing with ITA 301/2022 has sustained the said conclusion and gone on to hold that no substantial question of law arose for its consideration. It is th....