TMI Blog2023 (12) TMI 772X X X X Extracts X X X X X X X X Extracts X X X X ..... rned from Indian operations - whether the view taken by CIT(A) that 15 percent of the profits earned from Indian operations could be attributed to the respondent/assessee was sustainable? - HELD THAT:- The coordinate bench in AY 2006-07 while dealing with [ 2021 (10) TMI 1004 - ITAT DELHI ] has sustained the said conclusion and gone on to hold that no substantial question of law arose for its con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndonation of delay of 460 days in re-filing the appeal] CM APPL. 63598/2023 in ITA 722/2023 [Application filed on behalf of the appellant seeking condonation of delay of 460 days in re-filing the appeal] CM APPL. 63607/2023 in ITA 723/2023 [Application filed on behalf of the appellant seeking condonation of delay of 460 days in re-filing the appeal] CM APPL. 63623/2023 in ITA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4. Since we intend to decide the appeals on merits, we are inclined to condone the delay. 4.1 It is ordered accordingly. 5. The applications are disposed of. ITA 718/2023, ITA 722/2023, ITA 723/2023, ITA 724/2023, ITA 726/2023, ITA 728/2023, ITA 731/2023 6. These appeals concern Assessment Year (AY) 2007-08 [ITA 726/2023], AY 2008-09 [ITA 718/2023], AY 2009-10 [ITA 728/2023], ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Since the order of the Supreme Court refers to a judgment of this court, the order is extracted hereafter: 1. Delay of 146 days is condoned. 2. Learned Additional Solicitor General appearing for the petitioner has submitted that the issues which arise in this petition have been considered and held against the Revenue in [ Civil Appeal Nos. 6511- 6518/2010] DIT v. Travelport Inc. [20 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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