PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, NEW DELHI vs. GE HYDRO FRANCE

ITA - 472 / 2025HC Delhi23 September 20252 pages

For Petitioner: PUNEET RAI

AI SummaryRemanded

What did the High Court hold?

The High Court has not decided any substantive issues of the appeal in this order. The order primarily deals with procedural matters. The Court has condoned the delay in filing the appeal by the Revenue and has issued notice to the Assessee. Directions have been given for the parties to file written submissions and relevant judgments before the next hearing. Therefore, there is no finding on any issue, no reasoning provided, and no ratio decidendi established. No operative directions regarding the merits of the case have been issued, and no issues have been left undecided as the substantive hearing has not yet commenced.

What were the facts?

This matter comes before the Delhi High Court concerning an appeal filed by the Principal Commissioner of Income Tax (International Taxation)-1, New Delhi (the Revenue) against GE Hydro France (the Assessee). The appeal was filed with a delay of 175 days, which the High Court has condoned. The High Court has issued notice to the Assessee, who has accepted it. Both parties are directed to file their written submissions along with the judgments they intend to rely upon one week before the next date of hearing. The case is renotified for 10.11.2025. The specific assessment year(s) and the order or action under challenge are not detailed in this order.

What were the issues?

The High Court is seized of an appeal filed by the Revenue. The specific questions of law or mixed fact and law that the Tribunal had to decide are not recorded in this order. The arguments presented by the Assessee and the Revenue are also not detailed. The judgment does not mention any specific provisions of the Income Tax Act, circulars, or precedents relied upon by either party.

AI-generated summary — verify with the full judgment below

$~88 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 472/2025 PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Gibran, JSC, Mr. Ashvini Kumar, Mr. Rishabh Nangia, Advs. versus GE HYDRO FRANCE .....Respondent Through: Mr. Aditya Vohra and Mr. Tanmay Dhakras, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

23.09.2025 CM APPL. 60750/2025 1. Exemption allowed, subject to all just exceptions. 2. The application stands disposed of. CM APPL. 60751/2025 3. For the reasons stated in the application, the delay of 175 days in re- filing the appeal is condoned. 4. The application is disposed of. ITA 472/2025 5. Issue notice. Mr. Aditya Vohra, accepts notice for respondent. 6. Counsel for the parties to file their written submissions along with the 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 12:03:20

judgments they intend to rely upon, one week before the next date of hearing. 7. Renotify on 10.11.2025. V. KAMESWAR RAO, J VINOD KUMAR, J SEPTEMBER 23, 2025 ss 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 12:03:20

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