CIT v. Cisco Systems Services BV

456 ITR 50Reported decision2023#14216 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2024 to 2026.

Sections most often in play

Section 143(3)Section 144CSection 156Section 271(1)(c)Section 292BSection 250Section 274Section 254

Issues it is cited on

section 156section 292bsection 292section 144c(1)miscellaneous applicationsection 29dispute resolution panelconcealment of incomesection 144csection 254penalty under section 271(1)(c)draft assessment order

Judgments citing CIT v. Cisco Systems Services BV

Dy Commissioner of Income Tax (Int Tax.)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 7522/MUM/2025[2009-10]Status: DisposedITAT Mumbai30 Jan 2026AY 2009-10

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year : 2007-08 Ita No.7522/Mum/2025 Assessment Year : 2008-09 Assessment Year : 2009-10 Deputy Commissioner Of Income Tax (International Taxation) – 3(2)(1), Room No.614, Kautilya Bhavan, Bkc, ……………. Appellant Mumbai – 400051 V/S Marriott International Inc. 303A, 304, Fulcrum, B Wing, Sahar P & T Colony So, Mumbai – 400099 Pan: Aaecm8040K ……………. Respondent

For Appellant: Shri Paras SavlaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 143(3)Section 144C(1)Section 156Section 250Section 254Section 271(1)(c)

…d in ITAs No.3232 to 3235/Mum/2018, for the assessment years 2006-07 to 2009-10, allowed the additional grounds of appeal filed by the assessee following the decision of the Hon’ble Karnataka High Court in CIT vs. Cisco Systems Services BV, reported in (2023) 456 ITR 50 (Karn), observing as follows: - “010. We have carefully considered the rival contention and perused the orders of the lower authorities. Admittedly, in this case the draft assessment order is passed which is also accompanied by the notice of demand issued under section 156 of the income tax act on the same date along with the computation of tax pa…

Dy Commissioner of Income Tax (Int Tax.)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 7521/MUM/2025[2008-09]Status: DisposedITAT Mumbai30 Jan 2026AY 2008-09

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year : 2007-08 Ita No.7522/Mum/2025 Assessment Year : 2008-09 Assessment Year : 2009-10 Deputy Commissioner Of Income Tax (International Taxation) – 3(2)(1), Room No.614, Kautilya Bhavan, Bkc, ……………. Appellant Mumbai – 400051 V/S Marriott International Inc. 303A, 304, Fulcrum, B Wing, Sahar P & T Colony So, Mumbai – 400099 Pan: Aaecm8040K ……………. Respondent

For Appellant: Shri Paras SavlaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 143(3)Section 144C(1)Section 156Section 250Section 254Section 271(1)(c)

…d in ITAs No.3232 to 3235/Mum/2018, for the assessment years 2006-07 to 2009-10, allowed the additional grounds of appeal filed by the assessee following the decision of the Hon’ble Karnataka High Court in CIT vs. Cisco Systems Services BV, reported in (2023) 456 ITR 50 (Karn), observing as follows: - “010. We have carefully considered the rival contention and perused the orders of the lower authorities. Admittedly, in this case the draft assessment order is passed which is also accompanied by the notice of demand issued under section 156 of the income tax act on the same date along with the computation of tax pa…

Dy. Commissioner of Income Tax (Int Tax)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 7520/MUM/2025[2007-08]Status: DisposedITAT Mumbai30 Jan 2026AY 2007-08

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year : 2007-08 Ita No.7522/Mum/2025 Assessment Year : 2008-09 Assessment Year : 2009-10 Deputy Commissioner Of Income Tax (International Taxation) – 3(2)(1), Room No.614, Kautilya Bhavan, Bkc, ……………. Appellant Mumbai – 400051 V/S Marriott International Inc. 303A, 304, Fulcrum, B Wing, Sahar P & T Colony So, Mumbai – 400099 Pan: Aaecm8040K ……………. Respondent

For Appellant: Shri Paras SavlaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 143(3)Section 144C(1)Section 156Section 250Section 254Section 271(1)(c)

…d in ITAs No.3232 to 3235/Mum/2018, for the assessment years 2006-07 to 2009-10, allowed the additional grounds of appeal filed by the assessee following the decision of the Hon’ble Karnataka High Court in CIT vs. Cisco Systems Services BV, reported in (2023) 456 ITR 50 (Karn), observing as follows: - “010. We have carefully considered the rival contention and perused the orders of the lower authorities. Admittedly, in this case the draft assessment order is passed which is also accompanied by the notice of demand issued under section 156 of the income tax act on the same date along with the computation of tax pa…

Marriott International Inc, Mumbai vs. DCIT(It) - 3(2)(1), Mumbai

In the result, by allowing the additional ground raised by the assessee for all these four years, the draft assessment orders for those years are quashed and appeal of the assessee are allowed

ITA 3235/MUM/2018[2009-10]Status: DisposedITAT Mumbai29 Jan 2024AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Paras Savla/ Pratik Poddar, ARFor Respondent: Shri Ajay Kumar Sharma, CIT DR
Section 143Section 144CSection 156Section 254

…under section 156 of the income tax act on the same date along with the computation of tax payable by the assessee. We find that the issue is identical to the facts of the case of the Cisco Systems services BV decided by the honourable Karnataka High Court in 456 ITR 50 on 24/2/2023 wherein the facts were that the assessee received the notice of demand under section 156 of the income tax act 1961 along with the draft assessment order under section 143 (3) of the act passed by the learned AO. The honourable High Court held that provisions of section 144C lays down a detailed procedure wherein the assessing officer…

Marriott International Inc, Mumbai vs. DCIT (It) - 3(2)(1), Mumbai

In the result, by allowing the additional ground raised by the assessee for all these four years, the draft assessment orders for those years are quashed and appeal of the assessee are allowed

ITA 3234/MUM/2018[2008-09]Status: DisposedITAT Mumbai29 Jan 2024AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Paras Savla/ Pratik Poddar, ARFor Respondent: Shri Ajay Kumar Sharma, CIT DR
Section 143Section 144CSection 156Section 254

…under section 156 of the income tax act on the same date along with the computation of tax payable by the assessee. We find that the issue is identical to the facts of the case of the Cisco Systems services BV decided by the honourable Karnataka High Court in 456 ITR 50 on 24/2/2023 wherein the facts were that the assessee received the notice of demand under section 156 of the income tax act 1961 along with the draft assessment order under section 143 (3) of the act passed by the learned AO. The honourable High Court held that provisions of section 144C lays down a detailed procedure wherein the assessing officer…

Marriott International Inc, Mumbai vs. DCIT-(It)-3(2)(1), Mumbai

In the result, by allowing the additional ground raised by the assessee for all these four years, the draft assessment orders for those years are quashed and appeal of the assessee are allowed

ITA 3233/MUM/2018[2007-08]Status: DisposedITAT Mumbai29 Jan 2024AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Paras Savla/ Pratik Poddar, ARFor Respondent: Shri Ajay Kumar Sharma, CIT DR
Section 143Section 144CSection 156Section 254

…under section 156 of the income tax act on the same date along with the computation of tax payable by the assessee. We find that the issue is identical to the facts of the case of the Cisco Systems services BV decided by the honourable Karnataka High Court in 456 ITR 50 on 24/2/2023 wherein the facts were that the assessee received the notice of demand under section 156 of the income tax act 1961 along with the draft assessment order under section 143 (3) of the act passed by the learned AO. The honourable High Court held that provisions of section 144C lays down a detailed procedure wherein the assessing officer…

Marriott International Inc, Mumbai vs. DCIT (It)-3(2)(1), Mumbai

In the result, by allowing the additional ground raised by the assessee for all these four years, the draft assessment orders for those years are quashed and appeal of the assessee are allowed

ITA 3232/MUM/2018[2006-07]Status: DisposedITAT Mumbai29 Jan 2024AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Paras Savla/ Pratik Poddar, ARFor Respondent: Shri Ajay Kumar Sharma, CIT DR
Section 143Section 144CSection 156Section 254

…under section 156 of the income tax act on the same date along with the computation of tax payable by the assessee. We find that the issue is identical to the facts of the case of the Cisco Systems services BV decided by the honourable Karnataka High Court in 456 ITR 50 on 24/2/2023 wherein the facts were that the assessee received the notice of demand under section 156 of the income tax act 1961 along with the draft assessment order under section 143 (3) of the act passed by the learned AO. The honourable High Court held that provisions of section 144C lays down a detailed procedure wherein the assessing officer…

CIT v. Cisco Systems Services BV (456 ITR 50) — Cited in 7 Judgments | BharatTax