2021 (3) TMI 1420

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..... - HELD THAT:- From perusal of the judgment [ 2020 (12) TMI 738 - KARNATAKA HIGH COURT] it is clear that we have not expressed any opinion as to whether or not the decision of M/s. WIPRO LTD., supra apply to the case of the assessee. Therefore, it is clarified that it would be open for the assessee to contend before the Tribunal that the aforesaid decision does not apply to the case of the assess .....

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