AMADEUS IT GROUP SA vs. DEPUTY COMMISSIONER OF INCOME TAX
What did the High Court hold?
The Delhi High Court disposed of the present appeal and the pending application in terms of the judgments of a co-ordinate bench in similar matters concerning the appellant for earlier assessment years. The Court clarified that the final outcome of the dispute between the parties would be subject to the judgment of the Supreme Court in the pending Civil Appeals. The specific finding on the issue raised in the present appeal, beyond its similarity to previously decided matters, and the reasoning for the disposal in terms of prior judgments are not detailed. No issue was expressly left undecided.
What were the facts?
The appellant, Amadeus IT Group SA, filed an Income Tax Appeal (ITA) before the Delhi High Court challenging an order dated January 29, 2021, passed by the Income Tax Appellate Tribunal (ITAT) in ITA No. 7047/Del/2019 for Assessment Year 2016-17. The appellant's counsel admitted that the issue in the present appeal had already been decided by the High Court in the appellant's own case for earlier assessment years. Appeals against those decisions were pending before the Supreme Court. The counsel also stated that similar issues for Assessment Years 2007-08 to 2012-13 had been decided by the High Court in other appeals.
What were the issues?
1. Whether the issue raised in the present appeal has been decided by this Court in the appellant's own case for earlier assessment years, and if so, what is the implication for the present appeal? Assessee's contention: The assessee's counsel admitted that the issue raised in the present appeal has been answered by the High Court in the appellant's own case in ITA Nos. 191-193/2011, against which an appeal is pending before the Supreme Court. Similar issues for other assessment years have also been decided by the High Court in other appeals. Revenue's contention: No specific contention is recorded for the revenue in the provided text.
AI-generated summary — verify with the full judgment below
$~S-181 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 197/2022 & CM APPL.30897/2022 AMADEUS IT GROUP SA ..... Appellant Through: Mr.Udit Naresh, Advocate. versus DEPUTY COMMISSIONER OF INCOME TAX ..... Respondent Through: Mr.Sunil Agarwal, Sr.Standing Counsel with Mr.Tushar Gutpa, Jr.Standing Counsel and Mr.Utkarsh Tiwari, Advocate. CORAM: HON'BLE MR. JUSTICE MANMOHAN HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA O R D E R % 15.07.2022 Present Income Tax Appeal has been filed challenging the Order dated 29th January, 2021 passed by the Income Tax Appellate Tribunal (‘ITAT’) in ITA No.7047/Del/2019 for the Assessment Year 2016-17. Learned counsel for the Appellant fairly admits that the issue raised in the present appeal has been answered by this Court in appellant’s own case in ITA Nos. 191-193/2011 and appeal against the same is pending disposal before the Supreme Court being CA Nos.8055/2011 and 1596-98/2014. He states that similar issues raised in appeals for Assessment Years 2007-08 to 2012-13 have been answered by this Court in ITA Nos. 67/2021, 90/2021; ITA No. 93/2021 and ITA Nos. 82/2021, 83/2021, 85/2021 vide orders dated 09th March, 2021, 22nd March, 2021 and 23rd March, 2021 respectively. 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 15/06/2026 at 01:51:42
Accordingly, the present appeal along with pending application is disposed of in terms of the judgments of the Co-ordinate Bench referred to hereinabove. It is made clear that the final result qua the dispute between the parties will abide by the judgment of the Supreme Court in the Civil Appeals referred to hereinabove. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J JULY 15, 2022 TS 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 15/06/2026 at 01:51:42
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