What did the High Court hold?

The Tribunal held that no substantial questions of law arise for consideration. The nature of income remained the same, and the Revenue had accepted it as business income in earlier years.

The appeals involved identical issues to a previously dismissed case. The revenue sought to be taxed was similar to revenue that was the subject of a MAP (Mutual Agreement Procedure). The receipts arose from the same agreements as in earlier assessment years.

What were the issues?

Whether the nature of income in the hands of the assessee, arising from the same agreements, remains the same across different assessment years, even if not directly covered by a MAP for those specific years.

CIT vs Turner Broadcasting System Asia… | Delhi High Court 2026

$~13 & 23 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 7/2026 & CM APPL. 1440/2026 + ITA 9/2026 & CM APPL. 1479/2026 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-3, DELHI

.....Appellant

Through: Mr. Puneet Rai, SSC, Mr. Gibran, JSC and Mr. Ashvini Kumar and Mr. Rishabh Nangia, Advs.

versus

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC .....Respondent Through: Mr. Rohan Khan and Mr. Priyam Bhatnagar, Advs.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE VINOD KUMAR

09.01.2026 O R D E R 1. Learned counsel for the parties jointly submitted that in the present ITA No. 7/2026 for the Assessment Year 2022-23 and ITA No. 9/2026 for the AY 2018-19, the issues involved, are identical to one involved in ITA No.76/2025, which has been dismissed by the Coordinate Bench of this Court, vide its judgment dated 26.03.2025, while observing thus:- “13. There is no cavil that the nature of the revenue which is now sought to be taxed in AY 20-21 and AY 21-22 was similar to the revenue that was subject matter of MAP. It is correct that the issues determined under MAP are in relation to the specific assessment years and such determination cannot be extrapolated to other assessment years. However, the nature of income in the hands of the assessee remains 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 11:05:24

the same. Undisputedly, the receipts in the earlier assessment years, which were subject of resolution under MAP, arise from the same agreement(s). In the given facts, this court cannot be oblivious to the fact that the Revenue had accepted income of the assessee as business income. 14. Thus, in the peculiar facts of the present case, we are of the view that no substantial questions of law arise for consideration of this court. 15. Accordingly, the present appeals are dismissed. However, we clarify that the wider question of law is left open to be decided in an appropriate case.”

Following the aforesaid judgment and another judgment dated 04.08.2025 passed in ITA No. 232/2025 of this Court, these appeals are dismissed.

DINESH MEHTA, J

VINOD KUMAR, J JANUARY 9, 2026/cd

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 11:05:24

COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-3, DELHI vs. TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.

What did the High Court hold?

What were the facts?

What were the issues?

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