PRINCIPAL COMMISSIONER OF INCOME TAX-1 vs BOEING INDIA PVT. LTD.

Judgment text excerpt

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment Reserved on: 13.11.2025 Judgment delivered on: 16.03.2026 Judgment uploaded on: As per Digital Signature~ + ITA 586/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-1 .....Appellant versus BOEING INDIA PVT. LTD. .....Respondent Advocates who appeared in this case For the Appellant : Mr. Debesh Panda, SSC, Ms. Zehra Khan, JSC, Mr. Vikramaditya Singh, JSC, Ms. Nivedita, Ms.Delphina Shinglai, Mr. Harshpreet Singh, Ms. A. Shankar, Ms. Ravicha Sharma, Advocates. For the Respondent : Mr. Sachit Jolly, Sr Advocate with Ms. Sherry Goyal, Ms. Viyushti Rawat, Mr. Devansh Jain, Mr. Sohum Dua and Mr. A. Shankar Bajpai, Advocates. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT V. KAMESWAR RAO, J. 1. This appeal has been filed with the following prayers: “A. Admit the appeal on the substantial questions of law as proposed in Para 3, allow the same, and set aside the impugned judgment dated 27.03.2024 in ITA No.828/Del/2021 by the Hon‟ble ITAT; B. Grant such other relief as this Hon‟ble Court may deem fit Signature Not Verified Signed By:PRADEEP ITA 586/2025 Page 1 of 38 SHARMA Signing Date:16.03.2026 15:15:30 and proper.” 2. The present appeal has been filed by the appellant under Section 260A of the Income Tax Act, 1961 (the Act), against the judgment dated 27.03.2024 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No.828/Del/2021 whereby the ITAT has allowed the ITA in favour of the respondent. The ITAT, while relying upon the decision of the Supreme Court in the case of PCIT v. Maruti Suzuki (2020) 18 SCC 331 and of the judgment of a Coordinate Bench of this Court in the case of CIT v. Sony Mobile Communications India Pvt. Ltd. 2023/DHC/001366, had held that the final assessment order date