2024 (5) TMI 1718

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....cchita Shahi & Ms. Anuja Pethia, JSCs. For the Respondent : Mr. Deepak Chopra, Mr. Ankul Goyal & Mr. Priyam Bhatnagar, Advs. ORDER 1. We note that these appeals of the Department have framed the following questions of law for our consideration: "2.1 Whether Id. ITAT erred in deleting the addition made by the Assessing officer under section 40(a)(i) of the Income Tax Act, 1961? ....

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....ore us today it is admitted that the proceedings under Section 201 of the Act have been accorded a closure in terms of an order dated 10 December 2018 passed by the Income Tax Officer ["ITO"] and where it has on due consideration come to the following conclusions: "After considering all the facts it has come to the notice that except the Honda Car Japan all other affiliates do not have Pe....