THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. QUALCOMM INCORPORATED
What did the High Court hold?
The Delhi High Court condoned the delay in filing and re-filing the appeals. The Court noted that the issues raised were concluded by a previous judgment in ITA 63/2024, which was against the Revenue.
What were the facts?
The Revenue filed appeals against the order of the Income Tax Appellate Tribunal (ITAT) concerning Qualcomm Incorporated. The appeals were filed with significant delays.
What were the issues?
Whether the appeals filed by the Revenue were maintainable given the significant delay. The core issue was already decided in a prior appeal against the Revenue.
AI-generated summary — verify with the full judgment below
$~52 & 67 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 149/2024
THE COMMISSIONER OF INCOME TAX -
INTERNATIONAL TAXATION -3 ..... Appellant Through: Mr. Ruchir Bhatia, Sr. Standing Counsel along with Ms. Deeksha Gupta, Adv.
versus
QUALCOMM INCORPORATED
..... Respondent Through: Mr. Nishant Thakkar, Ms. Jasmin Amalsadvala and Mr. Nikhil Ranjan, Advs. 67 + ITA 151/2024
THE COMMISSIONER OF INCOME TAX -
INTERNATIONAL TAXATION -3 ..... Appellant
Through: Mr. Ruchir Bhatia, Sr. Standing Counsel along with Ms. Deeksha Gupta, Adv.
versus
QUALCOMM INCORPORATED
..... Respondent
Through: Mr. Nishant Thakkar, Ms. Jasmin Amalsadvala and Mr. Nikhil Ranjan, Advs.
CORAM:
HON'BLE MR. JUSTICE YASHWANT VARMA
HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR
KAURAV
01.03.2024 O R D E R
This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 14:02:42
CM APPL.12922/2024 (delay in filing) & CM APPL.12923/2024 (delay in refiling) in ITA 149/2024
CM APPL.13045/2024 (delay in filing) & CM APPL.13046/2024 (delay in refiling) in ITA 151/2024 Bearing in the mind the disclosures made, the delay of 31 days in filing the appeals and the delay of 490 days in re-filing the appeals is condoned. The applications shall stand disposed of. ITA 149/2024 & ITA 151/2024 On hearing Mr. Bhatia, learned counsel appearing for the appellant, we find that the issues raised here stand concluded against them in light of the judgment rendered by us in ITA 63/2024. Consequently, following that decision, these appeals shall stand dismissed.
YASHWANT VARMA, J.
PURUSHAINDRA KUMAR KAURAV, J MARCH 01, 2024/ RW This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 14:02:42
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