What did the High Court hold?

The High Court noted that a similar appeal by the revenue was pending before it and was listed for a future date. Consequently, the court issued notice to the respondents.

The Revenue filed appeals before the High Court against the orders of the ITAT concerning Hindustan Aqua Ltd. and HAL Offshores Ltd. The appeals involved identical issues.

What were the issues?

The primary issue was the identical nature of the legal questions raised in the pending revenue appeal before the High Court.

PCIT vs M/S Hal Offshores Ltd | Delhi High Court 2022

$~S-38 to 41 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 420/2022 PR COMMISSIONER OF INCOME TAX ..... Appellant Through: Mr.Zoheb Hossain, Sr.Standing Counsel with Mr.Vipul Agrawal and Mr.Parth Semwal, Jr.Standing Counsel. versus HINDUSTAN AQUA LTD. ..... Respondent Through: Mr.Gautam Jain, Advocate with Mr.Ajit Kumar Jha, Advocate. + ITA 421/2022 PR COMMISSIONER OF INCOME TAX ..... Appellant Through: Mr.Zoheb Hossain, Sr.Standing Counsel with Mr.Vipul Agrawal and Mr.Parth Semwal, Jr.Standing Counsel. versus HAL OFFSHORES LTD ..... Respondent Through: Mr.Gautam Jain, Advocate with Mr.Ajit Kumar Jha, Advocate. + ITA 422/2022 PR COMMISSIONER OF INCOME TAX ..... Appellant Through: Mr.Zoheb Hossain, Sr.Standing Counsel with Mr.Vipul Agrawal and Mr.Parth Semwal, Jr.Standing Counsel. 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 27/03/2026 at 13:34:02

versus M/S HAL OFFSHORES LTD ..... Respondent Through: Mr.Gautam Jain, Advocate with Mr.Ajit Kumar Jha, Advocate. + ITA 423/2022 PR COMMISSIONER OF INCOME TAX(CENTRAL) 2... Appellant Through: Mr.Zoheb Hossain, Sr.Standing Counsel with Mr.Vipul Agrawal and Mr.Parth Semwal, Jr.Standing Counsel. versus M/S HINDUSTAN AQUA LTD. ..... Respondent Through: Mr.Gautam Jain, Advocate with Mr.Ajit Kumar Jha, Advocate. CORAM: HON'BLE MR. JUSTICE MANMOHAN HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA O R D E R % 27.10.2022 Learned counsel for the appellants states that revenue’s appeal being ITA No.645/2019 involving identical issues is pending before this Court and the same is next listed on 19th December, 2022. Accordingly, issue notice. Mr.Gautam Jain, Advocate accepts notice on behalf of the respondents. 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 27/03/2026 at 13:34:02

List the matter for hearing and disposal on 19th December, 2022. It is made clear that no adjournment shall be granted on the next date of hearing. MANMOHAN, J MANMEET PRITAM SINGH ARORA, J OCTOBER 27, 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 27/03/2026 at 13:34:02

PR COMMISSIONER OF INCOME TAX vs. M/S HAL OFFSHORES LTD

What did the High Court hold?

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What were the issues?

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