PR. COMMISSONER OF INCOME TAX-6 vs. MCKINSEY KNOWELEDGE CENTRE INDIA PVT LTD

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ITA/82/2018HC DelhiDLHC01454721201709 August 2018Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court held that the question of law framed in ITA 461/2017 & ITA 526/2017 was decided against the assessee, leading to the dismissal of the assessee's appeals. Concurrently, the question of law framed in ITA 590/2017 & ITA 82/2018 was decided in favour of the assessee and against the revenue, resulting in the dismissal of the revenue's appeals. The reasoning for these decisions is not provided in this excerpt, as the court refers to a detailed judgment dated 09.08.2018 in ITA 461/2017 for further explanation. The operative direction for all appeals is dismissal. No issue was expressly left undecided.

What were the facts?

These appeals concern McKinsey Knowledge Centre India Pvt. Ltd. (the assessee) and the Principal Commissioner of Income Tax, Delhi-6 (the revenue). The appeals arise from orders passed by the Income Tax Appellate Tribunal (ITAT). The specific assessment years are not explicitly stated in this excerpt, nor is the amount in dispute. The procedural history involves appeals filed by both the assessee and the revenue before the High Court of Delhi, challenging the ITAT's decisions. The High Court is considering the questions of law framed in these appeals.

What were the issues?

The High Court had to decide the questions of law framed in ITA 461/2017 & ITA 526/2017, and ITA 590/2017 & ITA 82/2018. The judgment indicates that the question of law framed in ITA 461/2017 & ITA 526/2017 was answered against the assessee. Conversely, the question of law framed in ITA 590/2017 & ITA 82/2018 was answered against the revenue and in favour of the assessee. The specific provisions of the Income Tax Act, 1961, and the nature of these questions of law are not detailed in this excerpt. No specific arguments from the assessee or the revenue are recorded here, other than the outcome of the legal questions.

AI-generated summary — verify with the full judgment below

ITA 526/2017 & connected matters Page 1 of 2

* IN THE HIGH COURT OF DELHI AT NEW DELHI

Reserved on: 07.02.2018 Pronounced on: 09.08.2018 + ITA 526/2017

MCKINSEY KNOWLEDGE CENTRE INDIA PVT. LTD. ..... Appellant Through: Mr. Porus Kaka, Sr. Advocate with Mr. Divesh Chawla & Mr. Harpreet Singh Ajmani, Advocates.

versus

PR. COMMISSIONER OF INCOME TAX, DELHI-6 ..... Respondent Through: Mr. Rahul Chaudhary with Ms. Vibhooti Malhotra, Advocates.

+ ITA 590/2017

PR.COMMISSIONER OF INCOME TAX-6 ..... Appellant Through: Mr. Rahul Chaudhary with Ms. Vibhooti Malhotra, Advocates

versus

MCKINSEY KNOWLEDGE CENTRE INDIA PVT.LTD. ..... Respondent Through: Mr. Porus Kaka, Sr. Advocate with Mr. Divesh Chawla & Mr. Harpreet Singh Ajmani, Advocates.

+ ITA 82/2018

PR. COMMISSIONER OF INCOME TAX-6 ..... Appellant Through: Mr. Rahul Chaudhary with Ms. Vibhooti Malhotra, Advocates.

versus

ITA 526/2017 & connected matters Page 2 of 2

MCKINSEY KNOWELEDGE CENTRE INDIA PVT LTD

..... Respondent Through: Mr. Porus Kaka, Sr. Advocate with Mr. Divesh Chawla & Mr. Harpreet Singh Ajmani, Advocates.

CORAM:

HON'BLE MR. JUSTICE S. RAVINDRA BHAT HON'BLE MR. JUSTICE A.K. CHAWLA

MR. JUSTICE S. RAVINDRA BHAT

1.

The question of law framed in ITA 461/2017 & ITA 526/2017 is answered against the assessee; its appeals, therefore, have to fail. Likewise, the question of law framed in ITA 590/2017 & ITA 82/2018 is answered against the revenue and in favour of the assessee; the revenue’s appeals, too, have to fail. All the appeals (ITA 461/2017, ITA 590/2017, ITA 82/2018 & ITA 526/2017) are consequently dismissed, without order on costs. 2. For detailed judgment, the decision dated 09.08.2018 in ITA 461/2017 may be referred to.

S. RAVINDRA BHAT (JUDGE)

A.K. CHAWLA (JUDGE) AUGUST 9, 2018

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