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2020 (2) TMI 933

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..... TANT MEMBER AND SMT BEENA PILLAI, JUDICIAL MEMBER Revenue by: Ms. Neera Malhotra, CIT-DR Assessee by: Shri. Amit Gupta, CA ORDER Per Bench: These are cross appeal filed by assessee and Revenue for Assessment Years 2010-11 and 2011-12 and these are directed against two separate assessment orders of these two years dated 29.12.2014 for Assessment Year 2010-11 and dated 27.01.2016 for Assessment .....

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..... s judgment of Hon'ble Karnataka High Court. 4. We have considered the rival submissions. We find that this is an admitted position of fact that MAP has been concluded for both these two years in respect of assessee company's transaction with AE in US. Hence, the TP grounds raised by both sides in these two years do not survive and the same are rejected. In addition to this, there is only one Corp .....

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