COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI vs DXC TECHNOLOGY SERVICES (SINGAPORE) PTE LTD. (EARLIER KNOWN AS HP SERVICES (SINGAPORE) PTE LTD.)

Judgment text excerpt

$~90, 91 & 99 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 06.11.2025 + ITA 581/2025 + ITA 582/2025 + ITA 574/2025 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-1, DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Ashvini Kumar, Mr. Rishabh Nangia and Mr. Gibran, JSC. versus DXC TECHNOLOGY SERVICES SINGAPORE PTE LTD. (EARLIER KNOWN AS HP SERVICES SINGAPORE PTE LTD.) .....Respondent Through: Mr. Percy Pardiwala, Sr. Adv with Mr. Satyen Sethi, Mr. Arta Trana Panda, Ms. Gargi Sethee, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR V. KAMESWAR RAO , J. (ORAL) CM APPL. 69038/2025 & CM APPL. 69045/2025 (exemption) 1. Exemption is allowed subject to all just exceptions. 2. The application stands disposed of. CM APPL. 69039/2025(condonation) 3. For the reasons stated in this application, the delay of 566 days in refilling the appeal is condoned. 4. The application stands disposed of. CM APPL. 69046/2025(condonation) 5. For the reasons stated in this application, the delay of 553 days in Signature Not Verified Signed By:PRADEEP ITA 581/2025 & connected Page 1 of 9 SHARMA Signing Date:04.12.2025 10:40:39 refilling the appeal is condoned. 6. The application stands disposed of. ITA 581/2025 ITA 582/2025 ITA 574/2025 7. The challenge in these appeals by the appellant/Revenue is to an order dated 10.10.2023 passed by the Income Tax Appellate Tribunal (ITAT) in respect of 4 appeals related to the Assessment Years (AY) 2011-12 to 2014- 15. 8. Mr. Puneet Rai learned Senior Standing Counsel states that the appeal relatable to the AY 2013-14 shall be listed next week. 9. In any case he has made his submissions with regard to these three appeals in respect of orders framed under Section 143(3) read with Section 144C of the Income