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Assessee has raised the ground that the Learned CIT (A) has grossly erred in not appreciating that the appellant does not render any ground handling services and only render technical handling services even though it has been held that both are covered under Article 8 of the DTAA if rendered to IATP Pool Members.

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Section 147 of the Income Tax Act, 1961—Reassessment —Assessing Officer has prima facie reason to believe that there is escapement of income as no return was filed by the assessee which is admitted fact,thus, initiating proceedings u/s 148 are just and proper - AIR FRANCE V/s ADDI. CIT - [2020] 82 ITR (TRIB) 301 (ITAT-DELHI)