PR. COMMISSIONER OF INCOME TAX vs M/S. REMFRY AND SAGAR

Judgment text excerpt

$~64 to 67 and 70 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 15.10.2025 + ITA 525/2025 + ITA 526/2025 + ITA 527/2025 + ITA 528/2025 + ITA 531/2025 PR. COMMISSIONER OF INCOME TAX .....Appellant Through: Mr. Indruj Singh Rai SSC, Mr. Sanjeev Menon, Mr. Rahul Singh JSC and Mr. Gaurav Kumar, Adv. versus M/S. REMFRY AND SAGAR .....Respondent Through: Mr. Ajay Vohra, Sr. Adv. with Mr. Aditya Vohra and Tanmay Dhakras, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR V. KAMESWAR RAO , J. (ORAL) CM APPL. 65031/2025 at ITA 525/2025 CM APPL. 65033/2025 at ITA 526/2025 CM APPL. 65037/2025 at ITA 527/2025 CM APPL. 65039/2025 at ITA 528/2025 CM APPL. 65043/2025 at ITA 531/2025 1. For the reasons stated in the applications, the delay of 914, 719, 1198, 858 and 1408 days in filing ITA no. 525/2025, ITA no. 526/2025, ITA no. 527/2025, ITA no. 528/2025 and ITA no. 531/2025 respectively, is Signature Not Verified Signed By:PRAMOD ITA 525/2025 and connected matters Page 1 of 11 KUMAR VATS Signing Date:18.10.2025 14:52:11 condoned. 2. The applications are disposed of. ITA 525/2025 ITA 526/2025 ITA 527/2025 ITA 528/2025 3. All these appeals except the ITA no. 531/2025, whereas according to Mr. Indruj Rai, SSC, an additional substantial question of law has been proposed, are governed by judgment of this Court in ITA no. 199/2017 and connected appeal, with regard to the respondent/assessee herein. Mr. Rai states that the proposed substantial questions can be summed up as noted by this Court in paragraph 2 of the aforesaid judgment which we reproduce as under : “2. The appeals had come to be admitted on the following three primary questions as is evident from the order dated 07 March 2017 passed in ITA 199/2017 and which is reproduced hereinbe