COMMISSIONER OF INCOME TAX -INTERNATIONAL TAXATION-3 vs. SALESFORCE.COM SINGAPORE PTE. LTD.

PDF · subscribers
ITA/672/2025HC DelhiDLHC01093321202524 November 2025Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted that the issue was covered by its own prior judgments and that appeals against those judgments were dismissed by the Supreme Court. Therefore, no substantial question of law arose.

What were the facts?

The Revenue appealed an ITAT order that allowed the Assessee's appeal for AY 2022-23. The Revenue conceded that the issue was covered by previous High Court judgments in the Assessee's own case for earlier assessment years.

What were the issues?

Whether the present appeal raises a substantial question of law given previous High Court and Supreme Court judgments on the same issue for the Assessee.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

$~60 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 672/2025 COMMISSIONER OF INCOME TAX -INTERNATIONAL TAXATION-3 .....Appellant Through: Mr Ruchir Bhatia, SSC and Mr Anant Mann, JSC. versus SALESFORCE.COM SINGAPORE PTE. LTD. .....Respondent Through: Mr S S Tomar, Mr Vishal Kalra and Mr Anil Kumar, Advocates. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R % 24.11.2025 1. This appeal filed under Section 260A of the Income Tax Act, 1961 (the Act) lays challenge to the order dated 04.07.2025 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No.2119/Del/2025 which relates to the Assessment Year (AY) 2022-23 whereby the ITAT has allowed the appeal filed by the respondent/Assessee. 2. Mr Ruchir Bhatia, learned SSC appearing for the Appellant fairly states that the issue involved in this appeal is covered against the appellant/ Revenue and in favour of the respondent/Assessee relating to the earlier AYs 2010-11 to 2016-17, in terms of the judgment of this Court in Commissioner of Income Tax, International Taxation v. Sales Force.com Singapore PTE. Ltd 2024 165, Taxmann.com 580 (Delhi) and also ITA 567/2024 and ITA 568/2024 decided on 11.12.2024 and 12.12.2024 relatable AYs 2018-19 to 2021-22 in the Assessee’s own case. 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 28/11/2025 at 15:05:34

3.

We have been informed that the appeals against the aforesaid decisions of this Court have been dismissed by the Supreme Court. 4. If that be so, for parity of reasons, as no substantial question of law arises in this appeal, the same is dismissed. V. KAMESWAR RAO, J VINOD KUMAR, J NOVEMBER 24, 2025 M 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 28/11/2025 at 15:05:34

Recent GST High Court judgments

Search GST case law →