The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11
92C of the Act, and in the manner prescribed therein, I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 10 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. in good faith and due diligence. However, as clearly mentioned above that both Special bench and Ahmedabad ITAT has already taken a view against