THE PR COMMISSIONER OF INCOME TAX IV NEW DELHI vs NTPC VIDYUT VYAPAR NIGAM LTD

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 23.04.2025 ITA 260/2024 PR. COMMISSIONER OF INCOME TAX-4, NEW DELHI ..... Appellant Versus NTPC VIDYUT VYAPAR NIGAM LTD. ..... Respondent Advocates who appeared in this case: For the Appellant : Mr Shlok Chandra, senior standing counsel with Ms Naincy Jain and Ms Madhavi Shukla, Advocate For the Respondent : Mr Ved Jain and Mr Nischay Kantoor, Advocates. CORAM HON’BLE MR. JUSTICE VIBHU BAKHRU HON’BLE MR. JUSTICE TEJAS KARIA JUDGMENT VIBHU BAKHRU, J. 1. The appellant [Revenue] has filed the present appeal impugning an order dated 31.07.2023 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT] in ITA No.145/Del/2020 in respect of assessment year [AY] 2015-16. The said appeal was preferred by the respondent [Assessee] impugning an order dated 18.11.2019 passed by the Principal Commissioner of Income Tax [PCIT] under Section 263 of the Income Tax Act, 1961 [Act]. 2. In the aforesaid context, the Revenue has projected following questions of law for consideration of this court: “A. Whether on the facts, circumstances and law of the case, the Hon’ble ITAT was justified in holding that no addition of Rs