2023 (11) TMI 1198

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..... so that although the assessee(s) was not having any contract as such during the relevant period it was nevertheless engaged in business in the country and therefore, it was entitled to the benefit of deduction insofar as the expenses incurred are concerned. HELD THAT:- What is necessary to ascertain at this stage is the reason as to why the assessee(s) sought for rectification u/s 154 of the Act s .....

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..... ced by the next date of hearing. List on 29.11.2023.
HON'BLE MRS. JUSTICE B.V. NAGARATHNA And HON'BLE MR. JUSTICE S.V.N. BHATTI For the Appellant : Miss Geetanjali Mohan, AOR Mr. Rohit Jain, Adv. Mrs. Geetanjali Mohan, Adv. Mr. Vaibhav Kulkarni, Adv. Mr. Udit Naresh, Adv. For the Respondent : Mr. Balbir Singh, A.S.G. Mr. Raj Bahadur Yadav, AOR Mr. Arijit Prasad, Sr. Adv. Mr. H R Rao .....

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..... n the country and therefore, it was entitled to the benefit of deduction insofar as the expenses incurred are concerned. What is necessary to ascertain at this stage is the reason as to why the assessee(s) sought for rectification under Section 154 of the Act seeking a lesser rate of taxation to be imposed under the DTAA regime if the assessee(s) was not seeking to be taxed under the said regime. .....

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