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upon remitting the amount of Rs.17,89,00,521/- under Section 115QA of the Act, claiming refund ... account of the entire credit of taxes paid under Section 115QA of the Act not been given in favour of the petitioner and as such

scope of the provisions of Section 2(22) as well as Section 115QA of the Act and therefore cannot be treated as a colourable device ... collection and recovery of income-tax shall apply. Explanation... 81a[***] Section 115QA : Tax on distributed income to shareholder: (1) Not withstanding anything contained