2024 (9) TMI 95

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..... ht in holding that provisions of DTAA will override provisions of the Act when the same is against to provisions of section 206AA of the Act? As decided by HC as submitted that the issue involved in this appeal is covered by the decision of this Court in the case of M/s. Wipro Ltd. [ 2023 (1) TMI 173 - KARNATAKA HIGH COURT] The said submission is not disputed by Shri. M. Dilip for the appellants, .....

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..... Chandrashekhara Bharathi, Adv. Mr. Annirudh Sharma Ii, Adv. Mr. T A Khan, Adv ORDER UPON hearing the counsel the Court made the following. There is gross delay of 402 days in filing this Special Leave Petition. On perusal of the application seeking condonation of delay, neither are we satisfied with the reasons assigned for the same and nor are they sufficient in law to be condoned. Hence, the ap .....

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