2024 (11) TMI 1577

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....arma For the Appellant : Mr. Sunil Aggarwal, SSC, Mr Shivansh B Pandya, Mr Viplav Acharya, JSCs and Mr Utkarsh Tiwari, Advocate. For the Respondent : Mr. Nageswar Rao, Mr. Parth and Ms. Anshika Agarwal, Advocates ORDER 1. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 (hereafter the Act) impugning a judgment dated 06.12.2023 passed by the learne....

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.... this Court by an order dated 02.08.2024 on the ground that the appeal did not raise any substantial question of law. 3. The Revenue has projected the following question of law in the present case: "Whether on the facts and circumstances of the case, the Hon'ble ITAT erred in holding M/s NCR Corporation India Pvt. Ltd. is not PE of the assessee without appreciating the facts that it is....