Foseco India Ltd Company vs ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1) PUNE

Judgment text excerpt

31-ITXA-1029-2025.DOC Digitally signed by PRASHANT PRASHANT VILAS RANE VILAS Date: RANE 2026.04.27 20:28:23 Vidya Amin +0530 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 1123 OF 2025 Foseco India Ltd. Company … Appellant Versus Assistant Commissioner of Income Tax, Circle1(1), Pune … Respondents WITH INCOME TAX APPEAL NO. 1049 OF 2025 WITH INCOME TAX APPEAL NO. 1088 OF 2025 WITH INCOME TAX APPEAL NO. 1055 OF 2025 WITH INCOME TAX APPEAL NO. 1086 OF 2025 WITH INCOME TAX APPEAL NO. 1080 OF 2025 WITH INCOME TAX APPEAL NO. 1029 OF 2025 _________ Mr. Sagar Tilak a/w Sachin Hande, Preshita Adamane and Saachi Bhiwandkar i/b Sachin Hande for Appellant. Mr. N. Venkataraman, ASG a/w Sushma Nagaraj, Ms. Amira Razaq, Krithika Anand, Abhinav Palsikar, Chandrashekara Bharathi and Nakul Madhan i/b Sushma Nagaraj for Respondent. Mr. Vinod Tanwani (I.R.S.) (Principal Commissioner of Income Tax, Central – 3, Mumbai), representative of the Revenue, Present. __________ CORAM : G. S. KULKARNI & AARTI SATHE, JJ. RESERVED ON : 05 MARCH 2026 PRONOUNCED ON : 27 APRIL 2026 Oral Order : (Per G. S. Kulkarni, J.) 1. These are a batch of seven appeals filed under Section 260A of the Income Tax Act, 1961 (for short “IT Act”), challenging a common order dated 11 November 2024 passed by the Income Tax Appellate Tribunal, Bench at Pune, Page 1 of 42 2026 31-ITXA-1029-2025.DOC whereby, the appeals filed by the appellant/assessee challenging the orders passed by the Commissioner of Income Tax (Appeal), Pune (CIT)(A) are dismissed. The assessment years in question are assessment year 2014-15 to 2020-21. 2. The assessee has raised the following questions of law: I. Whether Dividend Distribution Tax (‘DDT’) prescribed under section 115-O of the Income-ta