COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, NEW DELHI vs FUJITSU LIMITED

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision : 08.07.2025 ITA 207/2025 COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, NEW DELHI .....Appellant Through: Mr Puneet Rai, SSC, Mr Ashvini Kumar, Mr Rishabh Nangia, Mr Gibran, JSCs and Mr Nikhil Jain, Ms Srishti Sharma and Mr Pratham Aggarwal, Advocates versus FUJITSU LIMITED .....Respondent Through: Mr Prakash Kumar and Ms Rashmi Singh, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (ORAL) CM APPL. 39441/2025(condonation of delay) 1. For the reasons stated in the application, the delay of 19 days in filing the captioned appeal is condoned. 2. The application stands disposed of. ITA 207/2025 & CM APPL. 39440/2025 3. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 [the Act], inter alia, impugning an order dated 20. 4. The respondent [Assessee] is engaged in providing information technology support, maintenance support and software licensing services to various group entities including its Indian Associated Enterprises (AEs). 5. The Assessee – a tax resident of Japan – had preferred the aforesaid appeal [ITA no.2607/Del/2022] bef