PRINCIPAL COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX)-1, NEW DELHI vs. GENERAL MOTORS COMPANY USA

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ITA - 372 / 2025HC Delhi01 September 20251 pages
For Petitioner: PUNEET RAI
AI SummaryPartly Allowed

What did the High Court hold?

The High Court, in this order, has condoned the delay of 166 days in re-filing and the delay of 8 days in filing the appeal by the Revenue. The Court found the reasons stated in the applications for condonation to be sufficient. Consequently, the applications for condonation stand disposed of. The High Court also granted exemption to the Revenue, subject to all just exceptions, and disposed of that application. The appeal itself has been re-notified for a future date, indicating that the merits of the appeal have not yet been decided. No finding on the substantive issues of the appeal has been made at this stage.

What were the facts?

This matter concerns an appeal filed by the Principal Commissioner of Income Tax (International Tax)-1, New Delhi (Revenue) against an order of the Income Tax Appellate Tribunal (ITAT). The appeal is against the ITAT's decision concerning assessment year(s) not explicitly stated in this order. The Revenue sought condonation for a delay of 166 days in re-filing and 8 days in filing the appeal. The High Court also granted exemption to the Revenue, subject to just exceptions. The appeal was re-notified for hearing on 08.09.2025 at the request of the Revenue's counsel. The respondent, General Motors Company USA, was not represented.

What were the issues?

The primary issue before the High Court is whether to condone the delay in filing the appeal by the Revenue. The Revenue has filed applications for condonation of delay in re-filing (166 days) and filing (8 days) the appeal. The Revenue's contention, as implied by the filing of these applications, is that there were sufficient reasons for the delay. No specific arguments from the Revenue regarding the merits of the appeal are recorded in this order. The respondent (General Motors Company USA) has not presented any arguments as they were not represented.

AI-generated summary — verify with the full judgment below

$~55 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 372/2025 PRINCIPAL COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX)-1, NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Ashvini Kr., Mr. Rishabh Nangia, Mr. Gibran, JSC. versus GENERAL MOTORS COMPANY USA .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R % 01.09.2025 CM APPL. 54910/2025(condon in filing) CM APPL. 54911/2025(condon in re-filing) 1. For the reasons stated in the applications, the delay of 166 days in re- filing and the delay of 8 days in filing the captioned appeal stands condoned. 2. The applications stand disposed of. CM APPL. 54909/2025(Exemption) 3. Exemption is allowed, subject to all just exceptions. 4. The application stands disposed of. ITA 372/2025 5. At the request of Mr Puneet Rai, learned counsel for the Revenue, renotify on 08.09.2025. V. KAMESWAR RAO, J VINOD KUMAR, J SEPTEMBER 01, 2025/M 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 12:33:51

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