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2018 (10) TMI 1999 - BOMBAY HIGH COURTApplicability of sections 10B(7) r.w.s. 80IA(10) - revision u/s 263 - HELD THAT:- As admitted on following substantial questions of law:- “Whether on the facts, circumstances of the case and in law, the Tribunal was justified in not appreciating the fact that that by arranging its affair with the AE, the assessee has inflated the profit in India on which deduction u/s 10B is claimed and assessee has arranged its transaction to evade the taxes and the provisions of sections 10B(7) r.w.s. 80IA(10) are clearly attracted in the assessee's case? (ii) Whether on the facts and circumstances of the case and in law, the ITAT was justified in holding that there is no merit in invoking jurisdiction by the Commissioner u/s 263 of the Act in this case?” We do not think that in the light of this order, we should reopen the finding of the Tribunal that Section 263 of the Income Tax Act, 1961 was not attracted. To be heard along with other Income Tax Appeal. Assessee waives service.
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