COMMISSIONER OF INCOME TAX vs BENETTON INDIA PVT. LTD.

Judgment text excerpt

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 06.02.2025 + ITA 472/2018 COMMISSIONER OF INCOME TAX .....Appellant Versus BENETTON INDIA PVT. LTD. .....Respondent + ITA 1318/2018 COMMISSIONER OF INCOME TAX .....Appellant Versus BENETTON INDIA PVT.LTD. .....Respondent + ITA 1319/2018 COMMISSIONER OF INCOME TAX .....Appellant Versus BENETTON INDIA PVT.LTD. ....Respondent Advocates who appeared in this case: For the Appellant: Mr. Shlok Chandra, SSC with Ms. Madhvi Shukla, Ms. Naincy Jain, JSCs and Mr. Sushant Pandey, Advocate. For the Respondent: Mr. Himanshu S. Sinha, Mr. Prashant Meharchandani, Mr. Vibhu Jain & Mr. Jainender Singh Kataria, Advocates. CORAM HON’BLE MR JUSTICE VIBHU BAKHRU HON’BLE MS JUSTICE SWARANA KANTA SHARMA Signature Not Verified Digitally Signed By:GANGA SINGH RAWAT ITA No.472/2018 & connected matters Page 1 of 41 Signing Date:11.02.2025 18:27:27 JUDGMENT VIBHU BAKHRU, J. 1. The Revenue has filed the above-captioned appeals under Section 260A of the Income Tax Act, 1961 (hereafter the Act) impugning the orders passed by the Income Tax Appellate Tribunal (hereafter ITAT) in respect of the assessment years (AYs) 2007-08, 2008-09 and 2009-10. 2. The learned ITAT had rejected the Revenue’s appeal (ITA No.457/Del/2013) in respect of the AY 2007-08 as well as the Revenue’s appeal (ITA No.458/Del/2013) in respect of the AY 2008- 09, by a common order dated 10.07.2017. The above-captioned appeals, being ITA 1318/2018 and 1319/2018, impugn the said common order dated 10.07.2017 in respect of AY 2007-08 and AY 2008-09. 3. In ITA No.478/2018, the Revenue impugns an order dated 27.10.2017 passed by the learned ITAT rejecting the Revenue’s appeal being ITA No.4229/Del/2014, in respect of AY 2009-10. The learned ITAT had rejected the said appeal