2013 (7) TMI 578

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..... t:- No justification for A.O. doing since proviso to applicable only after 1st April 2011 and not before that. - Special Appeal No. 316 to 338 of 2012 - - - Dated:- 28-5-2013 - BARIN GHOSH AND SERVESH KUMAR GUPTA, JJ. For the Appellant : Hari Mohan Bhatia. For the Respondent : P.R. Mullick, Chetan Joshi, Manoj Tiwari, K.K. Tiwari and Rishabh Maheshwari. JUDGMENT:- PER : Barin G .....

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..... those sections." 3. Whereas section 44BB deals with a non-resident assessee providing, amongst others, services or facilities in connection with prospecting for, or extraction or production of, mineral oils, the sections mentioned in the proviso, referred to above, deal with fees received by non-resident assessees for providing, amongst others, services or facilities. Therefore, by adding the pr .....

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