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2021 (9) TMI 123 - AT - Income TaxRectification of mistake - Income deemed to accrue or arise in India - determination of income attributable to India - as argued Tribunal while adjudicating the ‘Ground of appeal No. 6’ had failed to consider the main arguments /submissions of the assessee on the basis of which it had assailed the taxability of certain revenues in its hands, viz. (i). membership fees; (ii). fees for IATA Clearing House Facility (ICH facility); and (iii). BSP Link charges - HELD THAT:- As the Tribunal had failed to address and therein adjudicate the specific contentions that were raised by the assessee in the course of the hearing of the appeal in furtherance of its claim that the aforesaid revenues, viz. (i). membership fees; (ii). fees for IATA Clearing House Facility (ICH facility); and (iii). BSP Link charges were not taxable in India, therefore, to the said extent the order passed by it while disposing off the assessee’s appeal [2021 (6) TMI 2 - ITAT MUMBAI] suffers from a mistake which being apparent from record renders the order amenable for rectification under sub-section (2) of Sec. 254.
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