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Osi Systems Private Limited, Hyderabad vs Dy. Commissioner Of Income Tax , ... on 18 November, 2020

13. We have heard the rival contention and also gone through the record in light of the submissions made by either side. We have gone through the prospectus and we are of the view that, the reliance of the assessee on the prospectus, does not establish that the MPS itself is engaged in high-end service provision. We have also gone through the Page Nos. 738, 739 and 754 of the paper book which form part of annual report of MPS and found that MPS it is not engaged in Content 10 ITA No. 194/Hyd/2023 Development or high-end services. Further, we have also gone through the decision of this Tribunal in the case of OSI Systems Private Limited vs. Dy. Commissioner of Income Tax (supra), wherein at Paragraphs 16 to 18, the Tribunal has held as under:
Income Tax Appellate Tribunal - Hyderabad Cites 6 - Cited by 2 - Full Document
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