COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION-3 vs. THE BANK OF TOKYO-MITSUBISHI UFJ LTD.

$~32 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 1068/2017 COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION-3 ..... Appellant Through: Mr. Rahul Chaudhary, Sr. Standing Counsel with Mr. Sanjay Kumar, Jr. Standing Counsel versus THE BANK OF TOKYO-MITSUBISHI UFJ LTD. ..... Respondent Through: Mr. Sparsh Bhargava, Adv. CORAM: HON'BLE MR. JUSTICE S. RAVINDRA BHAT HON'BLE MR. JUSTICE SANJEEV SACHDEVA O R D E R % 28.11.2017 The two questions i.e. taxability of salaries and the applicability of Section 115JB of the Income Tax Act, 1961 are urged by the Revenue in its appeal. This Court notices that both the questions have been answered against the Revenue by this Court in its common order in Principal Commissioner of Income Tax Vs. Bank of Tokyo Mitsubishi UFJ Ltd. (In ITA 604-605/2015) decided on 08.04.2016 for two previous years. No question of law, therefore, arises. The appeal is therefore dismissed. S. RAVINDRA BHAT, J SANJEEV SACHDEVA, J NOVEMBER 28, 2017/‘rs’