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2018 (3) TMI 1508 - AT - Income TaxRectification of mistake U/s 254(2) - addition u/s section 40(a)(ia) - Held that:- As uphold the grievance of the assessee principally and direct that the AO shall give due and fair opportunity of hearing to the assessee and decide the matter afresh in accordance with law by way of a speaking order after carrying out necessary verification regarding impugned payments having been taken into account by the recipients in the computation of their respective income, regarding payment of taxes in respect of such income and regarding filing of related income tax return by the recipients. Hon'ble Supreme Court in the case of Palam Gas Service Vs CIT (2017 (5) TMI 242 - SUPREME COURT) is not at all applicable to the facts of the assessee’s case, therefore, the M.A. filed by the revenue has no merit and the same is dismissed. - Decided against revenue
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