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2007 (10) TMI 324 - ITAT DELHI-D
Extract:
.......ngs recorded by the CIT(A) have not been disputed during the course of argument. Considering the above, we are of the view that s. 9 of the IT Act and arts. 5 and 7 of the Indo-Italian Treaty are not applicable in this case. The learned CIT(A) was therefore justified in deleting the entire addition. 23. As a result Departmental appeal is dismissed.