What did the High Court hold?

The High Court found that the previous judgment concerning the assessee for AY 2008-09 covered the present appeal. Therefore, no substantial question of law arose for consideration.

The Revenue appealed against an ITAT order for AY 2011-12. The Revenue acknowledged that the issue was covered by a previous decision of a coordinate bench concerning the same assessee for AY 2008-09.

What were the issues?

Whether the issue raised in the appeal is covered by a previous decision of a coordinate bench concerning the same assessee for a different assessment year.

Pr Commissioner of Income Delhi 8 vs M/S Sony India Pvt. Ltd | Delhi High Court 2023

$~32 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 687/2023

PR COMMISSIONER OF INCOME DELHI 8 ..... Appellant Through: Mr Sanjeev Menon, Standing Counsel.

versus

M/S SONY INDIA PVT. LTD

..... Respondent

Through: Mr Nageshwar Rao with Mr Parth

and Ms Mehar Verma, Adv.

CORAM:

HON'BLE MR. JUSTICE RAJIV SHAKDHER

HON'BLE MR. JUSTICE GIRISH KATHPALIA

O R D E R %

05.12.2023 [Physical Hearing/Hybrid Hearing (as per request)] ITA 687/2023 1. This appeal concerns Assessment Year (AY) 2011-12. 2. Via the instant appeal, the appellant/revenue seeks to assail the order dated 14.05.2019 passed by the Income Tax Appellate Tribunal [in short, “Tribunal”]. 3. It is not in dispute that the Tribunal has relied upon the decision rendered by it which was confirmed by the coordinate bench concerning the respondent/assesee vis-à-vis AY 2008-09. 4. Given this position, Mr Sanjeev Menon, learned standing counsel, who appears on behalf of appellant/revenue cannot but accept that the same result will follow in the instant appeal. ITA 687/2023

Page 1 of 2 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 14:16:24

According to us, the judgment rendered by the coordinate bench rendered in Commissioner of Income Tax v Sony Mobile Communications 2019 SCC OnLine Del 8130, concerning the AY 2008-09, covers the issue raised in the instant appeal in favour of the respondent/asseessee. 6. Therefore, according to us, no substantial question of law arises for our consideration. 7. Accordingly, the appeal is closed. CM No.62537/2023 8. In view of the order passed in the appeal, the above-captioned application has been rendered infructuous. 9. The application is, accordingly, closed.

RAJIV SHAKDHER, J

GIRISH KATHPALIA, J DECEMBER 5, 2023/RY

Click here to check corrigendum, if any

ITA 687/2023

Page 2 of 2

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 14:16:24

PR COMMISSIONER OF INCOME DELHI 8 vs. M/S SONY INDIA PVT. LTD

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