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28. The aforesaid discussion made by us is bolstered by Order dated 29.11.2023 in W.P.(C) 15337 /2023 & CM Appl. 61508 / 2023 & CM Appl. 61509/2023 titled PPK Newsclick Studio This is a digitally signed order.
The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/05/2024 at 21:58:44 Pvt.Ltd. Vs. Principal CCIT, Central Delhi and Anr., wherein the present Applicant had approached Hon'ble High Court for stay of demand during the pendency of appeal before CIT(A). Hon'ble High Court, having taken note of the 'cogent findings' against the Applicant had concluded that Assessing Officer has virtually held that the transaction between the petitioner and the foreign entity was based on 'reverse engineering'. Relying the findings of the Assessing Officer , the Hon'ble High Court had concluded in Paragraph 8 as follows:-