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Computer Modelling Group Limited, ... vs Acit, Circle-1(2)(1), Int. Taxation, ... on 3 May, 2024
cites
Children Act, 1960
Article 12 in Constitution of India [Constitution]
Section 209 in The Income Tax Act, 1961 [Entire Act]
Article 7 in Constitution of India [Constitution]
Finance Act, 2012
Section 244A in The Income Tax Act, 1961 [Entire Act]
Dcit, New Delhi vs M/S. Ongc Videsh Ltd., New Delhi on 1 July, 2019
3. That the Ld. DRP and Ld. AO have grossly erred on facts and in
law while placing heavy reliance on the Hon'ble Supreme Court ruling in
the case of ONGC vs. CIT [2015] 59 taxmann.com 1 (SC), without
appreciating the aspect that eligibility of the taxpayers to the beneficial
provisions of DTAA (India-Canada DTAA in the present case), was not the
substantial question of law framed at all and was not adjudicated by
their lordships.