JCDECAUX SE vs. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2, NEW DELHI
What did the High Court hold?
The Delhi High Court allowed the application for withdrawal of the appeal. The Court reasoned that the appellant explicitly sought to withdraw the appeal to avail the benefits of the Direct Tax Vivad Se Vishwas Scheme, 2024. The application was allowed, and consequently, the appeal was dismissed as withdrawn. The next date of hearing was cancelled, and the application was disposed of. The operative direction was the dismissal of the appeal as withdrawn. No issues were decided on merits.
What were the facts?
The appellant, JCDECAUX SE, filed an appeal before the Delhi High Court against an order passed by the Commissioner of Income Tax (International Taxation)-2, New Delhi. The appeal was listed for hearing. The appellant, through its counsel, filed an application seeking withdrawal of the appeal. The reason stated for withdrawal was the appellant's intention to avail the remedy under the Direct Tax Vivad Se Vishwas Scheme, 2024 ('VSV Scheme'). The respondent was the Commissioner of Income Tax.
What were the issues?
1. Whether the appellant is permitted to withdraw the appeal to avail the remedy under the Direct Tax Vivad Se Vishwas Scheme, 2024? Assessee's Contention: The appellant, through its counsel, sought to withdraw the appeal, stating that it intended to avail the remedy under the Direct Tax Vivad Se Vishwas Scheme, 2024. No specific legal provision or precedent was cited in support of the withdrawal request, other than the intention to utilize the VSV Scheme. Revenue's Contention: The judgment does not record any specific contention from the revenue regarding the withdrawal of the appeal. The revenue was represented through its counsel, but their arguments on this specific point are not detailed in the order.
AI-generated summary — verify with the full judgment below
$~16 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 73/2025
JCDECAUX SE
…..Appellant Through: Mr. Prakash Kumar and Ms. Rashmi Singh, Advocates.
Versus
COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2, NEW DELHI .....Respondent Through: Mr. Shivendra Singh, JSC (through video conferencing)
CORAM:
HON'BLE MR. JUSTICE V. KAMESWAR RAO
HON'BLE MR. JUSTICE VINOD KUMAR
O R D E R %
25.07.2025
CM APPL. 44486/2025 1. Mr. Prakash Kumar, Advocate has drawn our attention to the application filed by the appellant seeking withdrawal of the appeal. He submits that he intends to withdraw the appeal as the appellant seeks to avail remedy under the Direct Tax Vivad Se Vishwas Scheme, 2024 (‘VSV Scheme’). 2. The application is allowed and the appeal is dismissed as withdrawn. 3. The next date of hearing fixed in the appeal as 15.10.2025 stands cancelled. 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 29/07/2025 at 12:45:08
The application stands disposed of.
V. KAMESWAR RAO, J
VINOD KUMAR, J JULY 25, 2025/acm 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 29/07/2025 at 12:45:08
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