TMI Blog2023 (5) TMI 1313X X X X Extracts X X X X X X X X Extracts X X X X ..... s, reservation service, technological service, operational service and training programs/human resources - HELD THAT:- Tribunal has noted, that the issue stands covered by the judgment of the coordinate bench in the case of Sheraton International Inc [ 2023 (4) TMI 1310 - DELHI HIGH COURT] As in the assessee s case for other AYs, the coordinate bench has followed the same approach i.e., accepted t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the appellant seeking condonation of delay in re-filing the appeal. 2. According to the appellant/revenue, the period of delay involved is 300 days. 3. Mr Divyanshu Agrawal, who appears on behalf of the nonapplicant/respondent, does not oppose the prayer made in the application. 4. Accordingly, the delay is condoned. 5. The application is disposed of in the aforesaid terms. ITA 294/2023 6. This ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rams/human resources. 10. The Tribunal has noted, that the issue stands covered by the judgment of the coordinate bench in the case of Director of Income Tax v. Sheraton International Inc (2009) 178 taxmann 84 (Del). 11. Furthermore, in the respondent/assessee s case for other AYs, the coordinate bench has followed the same approach i.e., accepted the ratio of the judgment in Sheraton Internationa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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