DY. COMMISSIONER OF INCOME TAX (INT TAX)- 3(2)(1)), MUMBAI vs. MERCEDES-BENZ GROUP AG, MUMBAI

PER BIJYANANDA PRUSETH, AM:

These two appeals filed by the revenue emanate from the orders passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act’) by the Commissioner of Income-tax (Appeals)-57, Mumbai [in short, ‘CIT(A)’], both dated 05.01.2026 for the assessment years (AY) 2018-19 and 2020-21. Since facts and the grounds are similar, with consent of both parties, the appeals were clubbed and heard together and a common order is passed for the sake of convenience and brevity. ITA No.2878/Mum/2026 (AY 2018-19) is taken as a “lead case.”