THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. ROCKWELL COLLINS INC

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ITA/464/2026HC DelhiDLHC01110570202503 August 2026Author: HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA,HON'BLE MR. JUSTICE DINESH MEHTA2 pages

AI SummaryDismissed

What did the High Court hold?

The High Court held that the issue in the present appeal was identical to the facts and law involved in the judgment dated 23.05.2025 passed by this Court in ITA No. 173/2025. Following its own prior judgment, the High Court dismissed the instant appeal. The reasoning was based on the principle of judicial precedent and the fact that the Revenue could not dispute the applicability of the earlier decision. The operative direction was the dismissal of the appeal. No issue was expressly left undecided.

What were the facts?

The Revenue, Commissioner of Income Tax - International Taxation -3, has appealed against an order dated 14.11.2024 passed by the Income Tax Appellate Tribunal (ITAT), Delhi Bench “D”. The ITAT had allowed the appeal filed by the respondent-assessee, Rockwell Collins Inc. The ITAT's decision was based on a co-ordinate bench ruling in Goodrich Corporation vs. ACIT. The assessee's counsel informed the High Court that this ITAT decision in Goodrich Corporation was affirmed by the High Court itself in ITA No. 173/2025 vide judgment dated 23.05.2025, and to their knowledge, no Special Leave Petition (SLP) was filed against it. The Revenue's counsel could not dispute this position.

What were the issues?

1. Whether the High Court should follow its own prior judgment dated 23.05.2025 in ITA No. 173/2025, which affirmed an ITAT order based on Goodrich Corporation vs. ACIT, when the present appeal under Section 260A of the Income Tax Act, 1961, involves identical facts and law. Assessee's Contention: The assessee argued that the present appeal should be dismissed as the issue is identical to the one decided by the High Court in ITA No. 173/2025, which affirmed the ITAT's reliance on the Goodrich Corporation judgment. They also stated that no SLP was filed against the High Court's earlier decision. Revenue's Contention: The Revenue's counsel was not in a position to dispute the assessee's submissions regarding the prior High Court judgment and the identical nature of the issue.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances

$~3 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC011105702025 + ITA 464/2026 & CM APPL. 37468/2026 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 .....Appellant Through: Mr. Ruchir Bhatia, SSC with Mr. Anant Mann, JSC and Mr. P. Gupta, JSC. versus ROCKWELL COLLINS INC .....Respondent Through: Mr. Kamal Sawhney, Mr. Puru Medhira and Mr. Nikhil Agarwal, Advs. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA

O R D E R % 03.08.2026

By way of instant appeal preferred under Section 260A of the Income Tax Act, 1961, the Revenue has assailed the order dated 14.11.2024 passed by the Income Tax Appellate Tribunal, Delhi Bench “D”, New Delhi [hereinafter referred to as ‘the Tribunal’] in 2410/Del/2023, whereby the appeal filed by the respondent/assessee has been allowed by relying upon the judgment of ITAT’ Co-ordinate Bench in Goodrich Corporation vs. ACIT in ITA No. 988/Del/2024. 2. Mr. Kamal Sawhney, learned counsel for the respondent, at the outset submitted that the said decision of the Tribunal has been affirmed by this 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 05/08/2026 at 11:45:34

Court vide judgment dated 23.05.2025 rendered in ITA No. 173/2025. He further submitted that, to the best of his information, no SLP has been filed thereagainst.

Mr. Ruchir Bhatia, learned Senior Standing Counsel for the appellant/Department is not in a position to dispute the aforesaid position.

Having heard learned counsel for the parties and upon perusal of the facts and law involved in present case vis-à-vis the facts and law involved in the judgment in Goodrich Corporation (supra), we are of the view that the issue is identical.

Hence, following the judgment dated 23.05.2025 passed by this Court, the instant appeal is also dismissed. Pending application also stands disposed of. DINESH MEHTA, J. RAJNEESH KUMAR GUPTA, J. AUGUST 3, 2026/ s 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 05/08/2026 at 11:45:34

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