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2026 (1) TMI 1689

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.... Syal, i/b Mint and Confreres,. P. C. 1. This Appeal is filed by the Revenue challenging the order passed by the ITAT dated 9th May 2019. 2. According to the Revenue, the following 3 questions of law arise for our consideration:- "i. Whether on the facts and circumstance of th case and in law, the Hon'ble ITAT was right in holding that the provisions of section 14A will not be ap....

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....ture on amortization of tenancy right is not of Capital nature failing to appreciate that the tenancy right acquired by the assessee has resulted in an enduring benefit?" 3. As far as questions (i) and (ii) are concerned, we find that the same are squarely covered by a decision of this Court in the case of Principal Commissioner of Income Tax-7 Vs. Morgan Stanley India Securities P Ltd [Income ....

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....e squarely covered by the decision of this Court in Morgan Stanley India Securities P Ltd (supra), we do not find that questions (i) and (ii) give rise to any substantial questions of law. 5. As far as question (iii) is concerned, we find that this issue also does not give rise to any substantial question of law. On this particular issue, the findings of the Tribunal can be found in paragraphs ....