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"5. Appellate Findings:

5.1 The appellant is in the business of wholesale trading of various products including multi-functional devices & accessories, printers and cameras, etc., together with providing service support and maintenance service to its customers. The appellant also provides software, developed in-house, to its ultimate parent company, Canon Inc., Japan. 5.2 Further, AO in his order u/s 201(1)/201(1A) of the Income Tax Act, 1961 observed and contended as below: -