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Addition u/s 94A - transactions with persons located in notified jurisdictional area - We note with the...

Addition u/s 94A - transactions with persons located in notified jurisdictional area - We note with the able assistance of both the parties that the CIT(A) has nowhere dealt with the Assessing Officer’s detailed discussion holding the impugned “CCDs” to be a sham transaction whilst deleting the additions in issue made u/s 94A of the Act. - The assessee’s plea before us is that this entire “sham transactions” issue has become redundant once the CIT(A) holds section 94A itself as not applicable. B..... .....

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