THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 vs ADOBE SYSTEMS SOFTWARE IRELAND LTD

IN THE HIGH COURT OF DELHI AT NEW DELHI ITA 32/2025, CM APPL. 7533/2025 & CM APPL. 7534/2025 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -1 .....Appellant Through: Mr. Ruchir Bhatia, SSC. versus ADOBE SYSTEMS SOFTWARE IRELAND LTD .....Respondent Through: Mr. Vishal Kalra, Advocate. Date of Decision: 7th February, 2025 CORAM: HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE TUSHAR RAO GEDELA JUDGEMENT TUSHAR RAO GEDELA, J.: (ORAL) CM APPL. 7533/2025 & CM APPL. 7534/2025 1. Cause shown is sufficient. Accordingly, the application is allowed. Delay of 164 days in filing as well as delay of 40 days in refilling the appeal is condoned. 2. The applications stand disposed of. ITA 32/2025 3. The present appeal has been filed under Section 260A of the Income Tax Act, 1961 assailing the order dated 09.02.2024 passed by the Income Tax Appellate Tribunal (ITAT) in respect of the respondent/Assessee for the Assessment Year (AY) 2021-22. 4. At the outset, Mr. Ruchir Bhatia, learned senior standing counsel counsel appearing for the revenue brings attention of this Court to para 2 of the appeal wherein substantial questions of law have been framed by the appellant, which reads thus:- “2.1