Pardiwalla, in this behalf placed
reliance on the decision rendered in Capgemini S.A. vs.
ADIT(International Taxation)14 by the Mumbai Bench ... subsequent decision rendered by the
Tribunal in yet another matter of Capgemini S.A. vs DCIT
(International Taxation)-2(1)(1), Mumbai15 and where
2017 Page 3 of 16
applicant relied upon the judgment of Capgemini India (P) Ltd
(Co. Scheme Petition No 434 of 2014, decided
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