PR. COMMISSIONER OF INCOME TAX-16 vs. DABUR INVEST CORP

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ITA/482/2019HC DelhiDLHC01022159201910 March 2025Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court found no justification to entertain the Revenue's appeals, noting the consistent favourable decisions for the assessee and the lack of distinguishing facts. The court emphasized the principle of consistency.

What were the facts?

The appeals concerned the tax treatment of 'Option Price Contribution' for multiple assessment years. The Income Tax Appellate Tribunal (ITAT) had consistently ruled in favour of the assessee on this issue.

What were the issues?

The primary issue was the taxability of 'Option Price Contribution' and whether the Revenue could distinguish the current assessment years from previous favourable rulings for the assessee.

AI-generated summary — verify with the full judgment below

$~21 to 24 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 482/2019

PR. COMMISSIONER OF INCOME TAX-16 .....Appellant Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Sehrawal, JSC.

versus

DABUR INVEST CORP

.....Respondent Through: Mr. M. P. Rastogi, Mr. Kaushik, Mr. Ram Naresh and Mr. Shivam Malik, Advs. 22 + ITA 483/2019

PR. COMMISSIONER OF INCOME TAX-16 .....Appellant Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Sehrawal, JSC.

versus

DABUR INVEST CORP

.....Respondent Through: Mr. M. P. Rastogi, Mr. Kaushik, Mr. Ram Naresh and Mr. Shivam Malik, Advs. 23 + ITA 902/2019

PR. COMMISSIONER OF INCOME TAX-16 .....Appellant Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Sehrawal, JSC.

versus

DABUR INVEST CORP

.....Respondent Through: Mr. M. P. Rastogi, Mr. Kaushik, Mr. Ram Naresh and Mr. Shivam Malik, Advs. 24 + ITA 903/2019

PR. COMMISSIONER OF INCOME TAX-16 .....Appellant Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Sehrawal, JSC.

versus

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 12/03/2025 at 11:48:12

DABUR INVEST CORP

.....Respondent Through: Mr. M. P. Rastogi, Mr. Kaushik, Mr. Ram Naresh and Mr. Shivam Malik, Advs.

CORAM:

HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR

O R D E R %

10.03.2025 1. We had taken note of the undisputed facts which had emerged from the record with respect to „Option Price Contribution‟ in our order of 08 April 2024. While passing that order, we had found and were apprised that the aforesaid question has been consistently answered in favour of the assessee right from Assessment Years [“AYs’”] 2002-03 to AY 2023-24. 2. We had also taken note of the judgment rendered by the Income Tax Appellate Tribunal [“ITAT”] itself dated 11 February 2021 yet again answering that question in favour of the assessee. Mr. Agrawal submits that the Revenue has filed an appeal against the aforesaid order bearing Diary No. 796375/2021. 3. However, and in light of the view which has been taken persistently coupled with the appellants failing to indicate any fact or facet which may distinguish the AYs‟ with which we are concerned in this batch, we find no justification to entertain these appeals. We in this regard bear in mind the principles of consistency 4. These appeals shall stand dismissed.

YASHWANT VARMA, J.

HARISH VAIDYANATHAN SHANKAR, J. MARCH 10, 2025/ DR 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 12/03/2025 at 11:48:12

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