2022 (9) TMI 1536

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..... th Article 12 of the India-USA Double Tax Avoidance Agreement (DTAA)? - As revenue says that the issue is covered against the revenue by the judgement titled Engineering Analysis Centre of Excellence Private Limited [ 2021 (3) TMI 138 - SUPREME COURT] and a review petition has been filed against the said judgement, which is pending consideration in the Supreme Court. HELD THAT:- We may note th .....

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..... (as per request) ] 1. These are appeals preferred by the revenue. 2. Mr Punit Rai, who appears on behalf of the appellant/revenue says that the issue which arises for consideration in the above-captioned matters is covered against the revenue by the judgement dated 02.03.2021, rendered by the Supreme Court in Civil Appeal Nos. 8733-34/2018, titled Engineering Analysis Centre of Excellence P .....

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