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Ishikawajma-Harima Heavy Industries ... vs Director Of Income Tax, Mumbai on 4 January, 2007

4.9 Since certain crucial aspects and facts related to two separate agreements and provisions of DTTA as well as decisions of Hon'ble Supreme Court in the case of Ishikawajma-Harima Heavy Industries Ltd (supra) have not examined by the authorities below; therefore, in the interest of justice, we remit this issue to the record of the AO for deciding the same after considering all the relevant facts as well as the decisions on the point.
Supreme Court of India Cites 50 - Cited by 83 - S B Sinha - Full Document
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