COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION- 2, NEW DELHI vs HYUNDAI ROTEM COMPANY

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 29.10.2025 ITA 304/2025 & CM APPL. 50009/2025 COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION-2, NEW DELHI .....Appellant versus HYUNDAI ROTEM COMPANY .....Respondent Advocates who appeared in this case For the Appellant: Mr. Sunil Agarwal, SSC Mr. Viplav Acharya, Ms. Priya Sarkar, JSC and Mr. Utkarsh Tiwari, Advocates. For the Respondent: Ms. Ananya Kapoor, Ms. Soumya Singh and Mr. Sumit Lalchandani, Advocates. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT V. KAMESWAR RAO, J. CM APPL. 50009/2025 (Condonation of delayin filing) 1. For the reasons stated in the application, the delay of 103 days in filing the appeal stands condoned. 2. The application stands disposed of. 3. The present appeal has been filed by the appellant who is the Commissioner of Income Tax (International Taxation)-2, New Delhi under Section 260A of the Income Tax Act, 1961 (the Act) against the impugned order dated 18.11.2024 passed by the Income Tax Appellate Tribunal, Delhi “I” Bench („ITAT‟) in ITA No.2027/Del/2022 for the Assessment Year (AY) 2018-19, with the following prayers:- ―(a) Allow this appeal