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2017 (8) TMI 725

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..... ying on The Commissioner of Income Tax, Nagpur Versus M/s. Ballarpur Industries Ltd. [2017 (8) TMI 610 - BOMBAY HIGH COURT ] . Addition in respect of income from gross fees for management and technical services - Held that:- Issue raised herein is concluded against the Revenue in view of decisions of this Court in Reliance Infrastructure Ltd. vs. Commissioner of Income Tax, City VI, Mumbai (201 .....

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..... stified in law in sustaining the deletion of ₹ 1,19,81,900/by the CIT (Appeals) on account of interest free loan given to Andhra Pradesh Rayons Limited? (ii) Whether on the facts and in the circumstances of the case, the Tribunal was justified in law in directing that deduction of royalty on bamboo exploited be allowed at rates other than those specified in the 1968 and 1947 agreements dr .....

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..... d order decided both the aforesaid questions in favour of respondent/assessee and against appellant/Revenue. (b) Therefore, in view of the reason stated in the order dated 13.07.2017 in Income Tax Reference No.3/1995, question Nos.1 and 2 raised herein are answered in the affirmative i.e. in favour of respondent/assessee and against appellant/Revenue. 4. Regarding question No.3 : (a) Mr. .....

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..... ive i.e. in favour of respondent/assessee and against the appellant/Revenue. 5. Regarding question No.4 : (a) Mr. Dewani, learned counsel appearing for the respondent/assessee, very fairly states that this issue stands concluded against respondent/assessee by the decision of the Apex Court in Britannia Industries Ltd. vs. C.I.T., 278 ITR 546 (SC). (b) In the above view, question No.4 is a .....

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