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Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA
56 266 (ELT) 422 (SC) ITAT NO. 06 OF 2022 AND ETC. BATCH Page 60 of 150 reliance was placed on the decision in Sesa Sterlite Limited Versus Assistant Commissioner of Income Tax and Others 57 for the proposition on whom the onus of proof would lie, reliance was placed on the decision of the Learned tribunal in PCIT, Kolkata