TUNGSTEN AUTOMATION ENGLAND LIMITED (FORMERLY KNOWN AS TUNGSTEN NETWORK LIMITED) vs DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE 3(1)(1) NEW DELHI

Judgment text excerpt

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 14.07.2025 + ITA 92/2025 and CM APPL. 22267/2025 TUNGSTEN AUTOMATION ENGLAND LIMITED (FORMERLY KNOWN AS TUNGSTEN NETWORK LIMITED) .....Appellant Versus DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE 3(1)(1) NEW DELHI .....Respondent AND + ITA 93/2025 and CM APPL. 22294/2025 TUNGSTEN AUTOMATION ENGLAND LIMITED (FORMERLY KNOWN AS TUNGSTEN NETWORK LIMITED) .....Appellant Versus DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE 3(1)(1), NEW DELHI .....Respondent Advocates who appeared in this case: For the Appellant : Mr Deepak Chopra and Ms Priya Tandon, Advocates. For the Respondent : Mr Sunil Agarwal, SSC with Mr Shivansh B. Pandya, Mr Viplav Acharya, Ms Priya Sarkar and Mr Utkarsh Tiwari, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA JUDGMENT Signature Not Verified Digitally Signed By:GANGA SINGH RAWAT ITA 92/2025 and ITA 93/2025 Page 1 of 49 Signing Date:14.07.2025 18:41:49 VIBHU BAKHRU, J 1. The appellant [Assessee] has filed the present appeals under Section 260A of the Income Tax Act, 1961 [the Act] impugning a common order dated 18.12.2024 passed by the Income Tax Appellate Tribunal [the Tribunal] in ITA Nos.2237/Del/2024 and 2238/Del/2024 captioned Tungsten Network Ltd. v. Deputy Commissioner of Income Tax in respect of the assessment years [AYs] 2016-17 and 2017-18. 2. The Assessee had preferred the said appeals before the Tribunal impugning separate assessment orders dated 12.03.2024 passed by the Assessing Officer [AO] under Section 147 read with Section 144 of the Act in respect of AYs 2016-17 and 2017-18. The final assessment orders were passed pursuant to directions issued by the Dispute Resolution Panel [DRP] under Secti