PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1 vs M/S AVERY DENNISON (INDIA) PVT. LTD.

Judgment text excerpt

$~62 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 01.12.2025 + ITA 690/2025 PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1 .....Appellant Through: Mr. Vipul Agarwal, SSC with Ms. Sakashi Shairwal, JSC, Mr. Akshat Singh, JSC, Ms. Harshita Kotru, Mr. G. Ranjan, Advs. versus M/S AVERY DENNISON (INDIA) PVT. LTD. .....Respondent Through: Mr. Vishal Kalra, Mr. S. S. Tomar and Mr. Anil Kumar, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON’BLE MS. JUSTICE MINI PUSHKARNA V. KAMESWAR RAO , J. (ORAL) CM APPL. 75255/2025, CM APPL. 75256/2025 1. For the reasons stated in the applications, the delay of 593 days in filing and 146 days in re-filing the present appeal stands condoned. 2. The applications stand disposed of. ITA 690/2025 3. The challenge in this appeal under Section 260A of the Income Tax Signature Not Verified ITA 690/2025 Page 1 of 7 Signed By:PRADEEP SHARMA Signing Date:03.12.2025 18:20:09 Act, 1961 (“Act”), is to an order dated 05.06.2023 whereby the Income Tax Appellate Tribunal (“ITAT”) has primarily decided two appeals being ITA 7960/Del/2019 and ITA 7961/Del/2019. The same relate to Assessment Years (“AYs”) 2012-13 and 2015-16. 4. Mr. Vipul Agarwal, learned Senior Standing Counsel for the appellant has filed a compilation of five documents, which also includes an order dated 05.09.2024 passed by this Court in ITA 430/2024 titled Pr. Commissioner of Income Tax-1 v. M/s Avery Dennison (India) Pvt. Ltd., which is an appeal arising from the same impugned order in ITA 7961/del/2020 relatable to the AY 2015-16 whereby the said appeal has been dismissed by this Court by stating in paragraphs 1 to 7 as under:- “1. The Principal Commissioner impugns the order of the Income Tax Appellate Tribunal (Tribunal) dated 05 June 2023 and posits the following