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14, de applicable w. e. f. 01. counsel, the Id. CIT(A) in the present case by n'ble Gujarat High Court e Shah vs ACIT and the h in the case of Shri (International Taxation) as decided the identical e case of Shri Jaswinder g as under: - course of the hearing had dated 15.02.2018 in ITA of Ashok Keshavlal