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$~33 & 34 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 115/2024, CM APPL. 8842/2024
CONVERGYS CUSTOMER MANAGEMENT GROUP INC.
(NOW KNOWN AS CONCENTRIX CVG CUSTOMER
MANAGEMENT GROUP INC.)
..... Appellant Through: Dr. Shashwat Bajpai, Mr. Mahir Khanna, Mr. Saransh Bhardwaj, Advs.
versus
ASSISTANT COMMISSIONER OF INCOME TAX,
INTERNATIONAL TAXATION, CIRCLE- 1 (2) (1) NEW
DELHI
..... Respondent Through: Mr. Aseem Chawla, SSC with Ms. Pratishtha Chaudhary, Mr. Aditya Gupta, Advs. 34 + ITA 116/2024, CM APPL. 8845/2024
CONVERGYS CUSTOMER MANAGEMENT GROUP INC.
(NOW KNOWN ASCONCENTRIX CVG CUSTOMER
MANAGEMENT GROUP INC.)
..... Appellant Through: Dr. Shashwat Bajpai, Mr. Mahir Khanna, Mr. Saransh Bhardwaj, Advs.
versus
ASSISTANT COMMISSIONER OF INCOME TAX,
INTERNATIONAL TAXATION, CIRCLE- 1 (2) (1) NEW
DELHI
..... Respondent Through: Mr. Aseem Chawla, SSC with Ms. Pratishtha Chaudhary, Mr. Aditya Gupta, Advs.
CORAM:
HON'BLE MR. JUSTICE YASHWANT VARMA
HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR
KAURAV
O R D E R %
14.02.2024 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 12:07:26
CM APPL. 8841/2024 (Ex.) in ITA 115/2024 CM APPL. 8844/2024 (Ex.) in ITA 116/2024
Allowed, subject to all just exceptions. Applications are disposed of. CM APPL. 8843/2024 (delay) in ITA 115/2024 CM APPL. 8846/2024 (delay) in ITA 116/2024 Bearing in mind the disclosures made, the delay in re-filing the appeals is condoned.
The applications shall stand disposed of.
ITA 115/2024 & ITA 116/2024
Our attention is drawn to the order dated 23 January 2024 passed in ITA 131/2021 and other connected matters. Learned counsels for parties are ad idem that the instant appeals raise identical questions. 2. We consequently admit the present appeals on the questions of law as framed in ITA 131/2021. Let the appeals be called again on 07.03.2024 i.e. the date already fixed. 3. Learned counsel for parties are granted liberty to place their Brief Synopsis of Submissions on record at least 48 hours prior to the date fixed. Those submissions shall refer to the pdf page numbers of the digital record of the Court wherever so required.
YASHWANT VARMA, J.
PURUSHAINDRA KUMAR KAURAV, J. FEBRUARY 14, 2024/neha 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 12:07:26