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1990 (12) TMI 123 - AT - Income TaxExtract: .......e assessee-company by virtue of operation of Article 23 of the DTA Agreement for reasons stated by us hereinabove. We direct accordingly. Ground Nos. 9 and 10 for the assessment year 1985-86 and 8 and 9 for the assessment year 1986-87 would therefore be treated as allowed. 11.to 23. These paras are not reproduced here as they involved minor issues.
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