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2017 (7) TMI 1248 - HC - Income TaxWe “Admit” the present appeal on following substantial question of law; A. Whether on the facts and circumstances of the case and in law, the Income Tax Appellate Tribunal was justified in deleting the disallowance of expenditure of ₹ 12,73,34,892/claimed by the assessee as reimbursement of cost of salary and other expenses to its holding company due to nondeduction of TDS under section 40(a)(ia) read with the provisions of the Double Taxation Avoidance Agreement with Singapore?
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