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2010 (10) TMI 713 - ITAT, CHENNAISection 172 - No objection certificate - Applicability of the DTAA - A perusal of the provisions of section 246A(1)(a) are also found to be substantially in pari materia with the provisions of section 246 in so far as the words used are "or to the amount of tax determined - As the assessee has challenged the amount of tax determined under the provisions of section 172(4) - Decided in favour of the assessee Assessee had not placed before the Assessing Officer necessary certificate being the double income-tax relief certificate when filing its return under section 172(2) - A perusal of the provisions of section 172 shows that it is applicable to the profits of non-residents from occasional shipping business - it is also noticed that the necessary double income-tax relief certificate has been issued on February 14, 2007 and March 22, 2007 and the assessment order under section 172(4) has been passed only on May 8, 2007 - In the result, both the Revenue's appeal and the assessee's cross-objection are dismissed
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