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Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR
22. The core issues before this Court revolve around the legality and appropriateness of the Tribunal’s approach, particularly whether invoking Section 40(a)(ia) was justified given the true nature of these payments and the manner in which they were calculated. A key point of contention is whether these payments, which were determined as fixed percentages