PR. COMMISSIONER OF INCOME TAX -7 vs. VERIZON COMMUNICATIONS INDIA PVT. LTD.

These are the applications filed on behalf of the appellant/revenue seeking condonation of delay. 2. According to the appellant/revenue, the period of delay involved in the above-captioned appeals is 288 days [ITA 186/2023], 285 days [ITA 187/2023] and 286 days [ITA 188/2023]. ITA 186-188/2023

Mr Rajeev Mishra, who appears on behalf of the non- application/respondent, does not oppose the prayer made in the applications. 4. The delay is, accordingly, condoned. The applications are disposed of. ITA 186/2023 ITA 187/2023 ITA 188/2023 5. These appeals concern Assessment Years (AY) 2010-11 [ITA 186/2023], 2015-16 [ITA 187/2023] and 2013-14 [ITA 188/2023]. 6. The Income Tax Appellate Tribunal [in short, the “Tribunal”], via the common impugned order dated 20.10.2021, has ruled in favour of the respondent/assessee on issues which arise for consideration before us. 6.1 The Tribunal, it appears, has relied upon its own judgment rendered in AY 2011-12. 7. We are informed by Mr Puneet Rai, learned senior standing counsel, who appears on behalf of the appellant/revenue, that an appeal under Section 260A of the Income Tax Act, 1961 [in short, “Act”] has been lodged with this Court challenging the Tribunal's order concerning AY 2011-12. 7.1 We are told by Mr Rai that in that case, Diary no.1190971 has been allocated by the Registry. 8. There are only two issues on which these appeals founded: (i) First, whether the Tribunal has erred in deleting the additions amounting to Rs.11,14,74,058/-, on account of disallowance under Section 80IA of the Act?