2023 (12) TMI 593

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..... vi) of the Income Tax Act, 1961, read with Article 12 of the India-USA Double Tax Avoidance Agreement (DTAA) - As petitioner submitted that there is a delay of 334 days in filing and further the issues which arise in this petition are covered by the judgment of this Court in the case of Engineering Analysis Centre of Excellence Private Ltd. [ 2021 (3) TMI 138 - SUPREME COURT] against the Departme .....

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