SHERATON OVERSEAS MANAGEMENT CORPORATION ,UTTARPRADESH vs. ACIT, CIRCLE-3(1)(2), INT. TAXATION, NEW DELHI

Since identical issues are involved in the captioned appeals they were heard together and are disposed of by this common order for the sake of convenience and brevity.

Since identical grounds have been taken in the captioned appeals for the sake of our convenience. We are taking grounds of ITA No.394/Del/2022 pertaining to A.Y. 2016-17:-

At the very outset the Counsel for the assessee stated that identical grievance have been considered by this Tribunal in a bunch of appeals bearing ITA No.2011,2012,2013,2015, 9265, 9689/Del/2019 in order dated 29.04.2022 and has decided the quarrel in favour of the assessee and against the revenue.

The DR could not bring any distinguishing decision in favour of the revenue.

We have given a thoughtful consideration to the orders of the authorities below. We find force in the contention of the Counsel because identical grievance have been heard and decided by this Tribunal (supra) in favour of the assessee and against the revenue. The relevant findings read as under :-

Respectfully following the decision of the coordinate Bench (supra) we direct the AO to delete the addition.

In the result, the appeals of the assessee are allowed.