2022 (7) TMI 1514

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....K. BILLAIYA, AM : ITA No.5880/Del/2018 and 5479/Del/2019 are two separate orders of the AO dated 06.07.2018 and 03.04.2019 respectively for A.Y.2015-16 and 2016-17 framed u/s.143 (3) r.w.s. 144C (1) of the Act. 2. Since the grievance is common in both these appeals they were heard together and are being disposed of by this common order for the sake of convenience and brevity. 3. The substantive....

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.... a company incorporated in Singapore and is a tax resident of Singapore. It is engaged in the business of providing digital transmission of data through international private line or multi-protocol label switching etc. to facilitate high speed data connectivity. 6. The assessee provides bandwidth services outside India to its customers. It has entered into Global Business Services Agreement with ....

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.... view of the coordinate Bench find support from the decision of the Hon'ble High Court of Delhi in the case of New Skies Satellite BV in ITA No. 473, 474 and 500/2014 and 244/2014 order dated 08.02.2016. The relevant findings of the Hon'ble High Court read as under :- 10. This controversy is now well settled by the Hon'ble Supreme Court in the case of Engineering Analysis Centre of Excellence Pri....