PR. COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION-2, NEW DELHI vs. HCL SINGAPORE PTE. LTD.

Exemption is allowed, subject to all just exceptions.

The application stands disposed of. CM APPL. 66130/2024 (delay)

For the reasons stated in the application, delay of 122 days in filing the present appeal is condoned.

Accordingly, the present application is disposed of. ITA 552/2024

The Revenue has preferred the present appeal under Section 260A of the Income Tax Act, 1961 (hereafter the Act) impugning a common order dated 20.12.2023 passed in ITA No. 537/Del/2021 in respect of assessment year (AY) 2012-13. The Revenue has projected the following questions for 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 12:43:59

Whether on the facts and circumstances of the case and in law, the Hon’ble ITAT has erred in holding that both HCLT and the Respondent-assessee are jointly rendering services and therefore, it is a case of revenue sharing between HCLT and the Respondent- assessee qua the foreign customers of HCLT?

Whether on the facts and circumstances of the case and in law, the impugned judgment is perverse to the extent that additional evidence filed on behalf of the Appellant has neither been admitted nor rejected?”