SIME DARBY ENGINEERING SDN BHD,MALAYSIA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2, INTERNATIONAL TAXATION, DEHRADUN, UTTARAKHAND
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Income Tax Appellate Tribunal, DELHI BENCH ‘DB’, NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL
PER SATBEER SINGH GODARA, JM:
These assessee’s twin appeals i.e., ITA Nos. 170 & 171/Del/2026; for assessment years 2011-12 & 2012-13; arise against the learned Deputy Commissioner of Income Tax, Circle- 2(International Taxation), Dehradun’s as many assessments dated 05.01.2026 framed as per the Dispute Resolution Panel ‘DRP’-2’s identical directions dated 19.12.2025, passed in DIN & order No. ITBA/AST/M/143(3)/2025-26/1084457639(1),
2 involving proceedings u/s 143(3)/144C(1) of the Income
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