THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.

ITA - 443 / 2023HC Delhi11 August 20232 pages

For Petitioner: RUCHIR BHATIA

AI SummaryRemanded

What did the High Court hold?

The High Court did not decide the merits of the appeals. Instead, it noted that the Revenue had filed appeals for AYs 2016-17 and 2017-18, and also for several other AYs (2009-10 to 2015-16). For the other AYs, notices had been issued, and those appeals were listed for hearing on 16.10.2023. Consequently, the High Court directed that the present appeals (for AYs 2016-17 and 2017-18) be listed on the same date, i.e., 16.10.2023. No findings on any specific issues or operative directions were given, other than adjourning the hearing.

What were the facts?

These appeals, ITA 443/2023 and ITA 445/2023, are filed by the Commissioner of Income Tax - International Taxation - 3 (the Revenue) against Turner Broadcasting System Asia Pacific Inc. (the Assessee). The appeals pertain to Assessment Years (AYs) 2016-17 and 2017-18, respectively. The Revenue has also filed appeals for other AYs, namely 2009-10, 2010-11, 2011-12, 2012-13, 2013-14, and 2015-16, for which notices have been issued. The present appeals were listed before the Delhi High Court.

What were the issues?

The High Court was to decide the appeals filed by the Revenue concerning AYs 2016-17 and 2017-18. The judgment does not explicitly frame the specific legal or factual questions that the Tribunal had to decide. However, the context indicates that the appeals are against orders passed by an authority under the Income Tax Act, 1961, and the Revenue is challenging these orders. The Revenue, through its counsel Mr. Ruchir Bhatia, informed the Court about the listing of appeals for other AYs. The Assessee was represented by Mr. Rohan Khare. No specific arguments or contentions of either the Assessee or the Revenue regarding the merits of the appeals are recorded in this order.

AI-generated summary — verify with the full judgment below

$~44 & 46 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 443/2023 + ITA 445/2023 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3

..... Appellant Through: Mr Ruchir Bhatia, Sr. Standing Counsel.

versus

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.

..... Respondent

Through: Mr Rohan Khare, Advocate.

CORAM:

HON'BLE MR JUSTICE RAJIV SHAKDHER

HON'BLE MS JUSTICE TARA VITASTA GANJU

O R D E R %

11.08.2023 [Physical Hearing/Hybrid Hearing (as per request)] CM APPL. 41210/2023 in ITA 445/2023 1. Allowed, subject to just exceptions. ITA 443/2023 ITA 445/2023 2. These appeals concern Assessment Years (AYs) 2016–17 [in ITA 443/2023] and 2017-18 [in ITA 445/2023]. 3. We are informed by Mr Ruchir Bhatia, learned senior standing counsel, who appears on behalf of the appellant/revenue, that for the other AYs i.e., AYs 2009-10, 2010-11, 2011-12, 2012-13, 2013-14 and 2015-16, notice has been issued in the appeals preferred by the appellant/revenue, which are listed before the court on 16.10.2023. ITA 443/2023 & connected appeal

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 12:43:31

Accordingly, list the above-captioned appeals on the same date i.e., 16.10.2023

RAJIV SHAKDHER, J

TARA VITASTA GANJU, J

AUGUST 11, 2023 / tr

Click here to check corrigendum, if any

ITA 443/2023 & connected appeal

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 12:43:31

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