VIACOM 18 MEDIA PVT LTD vs DY. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-4(3)(1)

Judgment text excerpt

SAYYED Digitally signed by SAYYED SAEED SAEED ALI ALI AHMED ALI ITXA.1378.18 AND ORS.DOCX AHMED Date: 2025.05.08 ALI 14:55:08 +0530 Revati IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.1378 OF 2018 WITH INCOME TAX APPEAL NO.725 OF 2015 WITH INCOME TAX APPEAL NO.763 OF 2015 WITH INCOME TAX APPEAL NO.797 OF 2015 WITH INCOME TAX APPEAL NO.800 OF 2015 WITH INCOME TAX APPEAL NO.1661 OF 2014 WITH INCOME TAX APPEAL NO.1662 OF 2014 WITH INCOME TAX APPEAL NO.1658 OF 2014 VIACOM 18 MEDIA PVT LTD … Appellant Zion Bizworld, Subhash Road, A, Near Garware Office, Vile Parle (East) Mumbai-400057. Versus Deputy Commissioner of Income Tax … Respondent International Taxation-4(3)(1) Air India Building, Nariman Point, Mumbai-400021. ______________________________________________________ Mr Madhur Agrawal, Mr Atul Jasani, Mr Ketan Dave and Mr Pratik Shah i/b. Atul K Jasani for the Appellant. Mr Subir Kumar a/w Ms Niyanta Trivedi, Ms. Akshata Chhabra and Mr. Darshil Desai for the Respondent. ______________________________________________________ CORAM : M.S. Sonak & Jitendra Jain, JJ. RESERVED ON: 6 May 2025 PRONOUNCED ON : 8 May 2025 Judgment (Per Jitendra Jain, J.):- Page 1 of 24 ITXA.1378.18 AND ORS.DOCX 1. This group concerns different assessment years with respect to the same Appellant-Assesssee. Since it raises common substantial questions of law, it is disposed of by a common order with the parties’ consent. Furthermore, by consent, Income Tax Appeal No.1378 of 2018 for the Assessment Year (AY) 2013-14 is taken as the lead matter. 2. The details of the appeals and the corresponding assessment years are as under: - Sr. nos. ITXA A.Y. 1. 1378/2018 2013-2014 2. 725/2015 2011-2012 3. 763/2015 2012-2013 4. 797/2015 2012-2013 5. 800/201