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2022 (7) TMI 1292 - AT - Income TaxRectification u/s 254 - entitled for the deduction u/s 80IC and violation of sub rule (4) of Rule 18BBB - HELD THAT:- On going to the page 9 at para 4, we find that the issue of section 80IA(7) and 80IC(7) have been examined and dealt by the Co-ordinate Bench of the Tribunal. The Tribunal has also examined the remand report of the AO and also the applicability of Rule 18BBB and provision of section 80IA(8) and 80IA(12). Further, the Tribunal has also examined the application of section 80IA(8) and 80IA(10) and considered the decision has been taken to restore the issue back to the file of the AO. Placing reliance on the judgment of Hon’ble Apex Court in the case of CIT (Intl. Taxation-4), Mumbai Vs. M/s Reliance Telecom Ltd. [2021 (12) TMI 211 - SUPREME COURT] and CIT (Intl. Taxation-4), Mumbai Vs. M/s Reliance Communications Ltd. [2021 (12) TMI 211 - SUPREME COURT] we hold that the MA filed before the Tribunal beyond the provision of section 254(2) and hence being dismissed herewith. MAs of the assessee are dismissed.
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