CIT v. HEG Ltd.

263 ITR 230High Court2003#1483 most cited

What is CIT v. HEG Ltd. authority for?

Payments made for mere information, not involving the imparting of secret, confidential, or specialized technical, industrial, commercial, or scientific knowledge, experience, or skill, do not qualify as 'royalty' under Section 9(1)(vi) of the Income Tax Act or relevant DTAA articles. Not every piece of commercial information constitutes royalty; expertise or skill in providing it is required.

77

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2025.

Also referred to as

CIT v. HEG Ltd. · section 9(1)(vi) · section 195 · royalty income · definition of royalty · information as royalty · tax treaty · withholding tax · DTAA royalty · expertise or skill · commercial information

Sections most often in play

Section 195Section 143(3)Section 13(3)Section 195(2)Section 9(1)(vi)Section 195(1)Section 11(3)(a)Section 12

Issues it is cited on

copyrighted articlesection 195(2)royalty incomewithholding taxsection 9(1)(vi)computer softwaretax treatysection 195section 9(1)dependent agent pefixed place pedouble taxation

Judgments citing CIT v. HEG Ltd.

DCIT(IT)-2(1)(2),MUMBAI, MUMBAI vs. DELOITTE TOUCH TMATSU INDIA LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4655/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Dec 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP). In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that the…

DCIT(IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE HASKIN & SELLS LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4654/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Dec 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP). In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that the…

DCIT(IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE HASKIN & SELLS LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4653/MUM/2025[2020]Status: DisposedITAT Mumbai17 Dec 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP). In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that the…

DCIT(IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE TOUCH TMATSU INDIA LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 4638/MUM/2025[2021]Status: DisposedITAT Mumbai17 Dec 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP). In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that the…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2 MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals filed by the Revenue are dismissed

ITA 3455/MUM/2025[2021-22]Status: DisposedITAT Mumbai17 Dec 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 195Section 195(2)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP). In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that the…

ASST. COMMISSIONER OF INCOME TAX(IT)-2(1)-2 MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 2723/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Aug 2025AY 2019-20

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2019-20

For Appellant: Shri Niraj Sheth and Ms. Darshana Shah, AdvocatesFor Respondent: Shri Krishna Kumar, Sr. DR
Section 195(1)Section 195(2)Section 9(1)(vi)

…ll as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP) In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that ther…

M/s Modi Builders AND Realtors (P) Ltd., vs. Asst. Commissioner of Income tax,

The appeals are disposed of

ITTA/167/2012HC Telangana21 May 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 244ASection 260A

…to the principle of compensation when money, which is due and payable and refundable, is not paid. 13. Madhya Pradesh High Court had the occasion to deal with the similar issue in their decision in Commissioner of Income Tax versus HEG Limited, [2009] 310 ITR 341 (MP). The facts of the said case may be noticed. The assessee became entitled to refund along with interest under Section 244A. Referring to Section 240 of the Act, the High Court observed that the term used was ―refund of any amount becomes due to the assessee‖. The same words were also used in Section 244A. Reference was made to the d…

INTERNATIONAL AIR TRANSPORT ASSOCIATION,MUMBAI (FOR SENDING NOTICES) vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) - CIRCLE 2(2)(1), MUMBAI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 3330/MUM/2023[2020-21]Status: DisposedITAT Mumbai29 Apr 2025AY 2020-21

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3330/Mum/2023 (निर्धारण वर्ा / Assessment Year :2020-21) International Air V/S. Dcit (It), Circle 2(2)(1), Transport Association बिधम Mumbai C/O Ernst & Young Llp Room No. 1722, 17Th Floor, 14Th Floor, The Ruby, 29, Air India Building, Senapati Bapat Marg, Nariman Point, Mumbai, Dadar (West), Mumbai, Maharashtra-400021 Maharashtra-400028 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci4695N Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Porus Kaka and Shri DiveshFor Respondent: Shri Krishna Kumar

…IN THE INCOME-TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER & SMT. RENU JAUHRI, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 3330/MUM/2023 (निर्धारण वर्ा / Assessment Year :2020-21) International Air v/s. DCIT (IT), Circle 2(2)(1), Transport Association बिधम Mumbai C/o ERNST & Young LLP Room No. 1722, 17th Floor, 14th Floor, The Ruby, 29, Air India Building, Senapati Bapat Marg, Nariman Point, Mumbai, Dadar (West), Mumbai, Maharashtra-400021 Maharashtra-400028 स्थायी लेखा सं./जीआइआर सं./PAN/GIR No: AACCI4695N Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assess…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAITAX, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 5091/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Mar 2025AY 2019-20
Section 195(2)Section 9(1)(vi)

…contemplated in the definition of royalty as contained in clause (iv)\nof Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the\nIndia-UK tax treaty. In support of his contention, he relied upon\nthe following decisions :\n\n\"α. CIT vs. HEG Ltd. 263 ITR 230 (MP)\nIn this case, the assessee had paid certain amounts to a USA company\nfor purchase of some information. The transaction was held by the AO to\ninvolve imparting of information concerning technical, industrial,\ncommercial or scientific knowledge, experience or skill and, therefore, the\npayment was held to be royalty. The Tribunal held that…

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 5089/MUM/2024[2019-20]Status: DisposedITAT Mumbai21 Mar 2025AY 2019-20
Section 195(2)Section 9(1)(vi)

…\ncontemplated in the definition of royalty as contained in clause (iv)\nof Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the\nIndia-UK tax treaty. In support of his contention, he relied upon\nthe following decisions :\n\"α. CIT vs. HEG Ltd. 263 ITR 230 (MP)\nIn this case, the assessee had paid certain amounts to a USA company\nfor purchase of some information. The transaction was held by the AO to\ninvolve imparting of information concerning technical, industrial,\ncommercial or scientific knowledge, experience or skill and, therefore, the\npayment was held to be royalty. The Tribunal held that…

DCIT(IT)-2(1)-2, MUMBAI, MUMBAI vs. DELOITTE HASKINS & SELLS LLP, MUMBAI

In the result, all the appeals of the assessees are allowed

ITA 5715/MUM/2024[2019-20]Status: DisposedITAT Mumbai18 Feb 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 195Section 195(1)Section 195(2)Section 9(1)(vi)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP) In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that ther…

DCIT (IT)-2(1)(2), MUMBAI, MUMBAI vs. DELOITTE HASKINS SELLS LLP, UK

In the result, all the appeals of the assessees are allowed

ITA 4517/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Jan 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Krishna Kumar, Sr. DR
Section 195(2)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP) In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that ther…

DCIT (IT)-2(1)(2),MUMBAI, MUMBAI vs. DELOITTE TOUCHE TOHMATSU INDIA LLP, UK

In the result, all the appeals of the assessees are allowed

ITA 4515/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Jan 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Krishna Kumar, Sr. DR
Section 195(2)

…ill as contemplated in the definition of royalty as contained in clause (iv) of Explanation 2 to section 9(1)(vi) or under article 11(3)(a) of the India-UK tax treaty. In support of his contention, he relied upon the following decisions : “a. CIT vs. HEG Ltd. 263 ITR 230 (MP) In this case, the assessee had paid certain amounts to a USA company for purchase of some information. The transaction was held by the AO to involve imparting of information concerning technical, industrial, commercial or scientific knowledge, experience or skill and, therefore, the payment was held to be royalty. The Tribunal held that ther…

INTERNATIONAL AIR TRANSPORT ASSOCIATION (CANADA) ,MUMBAI vs. ACIT (IT), RANGE 2 (2)(1), MUMBAI

Accordingly Ground No. 3 to 7 are allowed

ITA 7117/MUM/2019[2016-17]Status: DisposedITAT Mumbai08 Jan 2025AY 2016-17

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Porus Kaka, Shri DiveshFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 234A

…ls cannot be brought within the realm of the definition of „royalty‟ as provided in Article 12(3) of the IndiaCanada tax treaty. Our aforesaid view is fortified by the judgment of the Hon’ble High Court of Madhya Pradesh in the case of CIT Vs. HEG Ltd. (2003) 263 ITR 230 (MP). In the said case, it was observed by the Hon‟ble High Court that it is not any information concerning the industrial or commercial venture that could earn the status as that of International Air Transport Association (Canada) royalty, as some expertise or skill in providing of such information would be required. In this regard, it was obser…

INTERNATIONAL AIR ASSOCIATION (CANADA),MUMBAI vs. ASST CIT (INTERNATIONAL TAXATION) RANGE 2 (2)(1), MUMBAI

Accordingly Ground No. 3 to 7 are allowed

ITA 7072/MUM/2019[2011-12]Status: DisposedITAT Mumbai08 Jan 2025AY 2011-12

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Porus Kaka, Shri DiveshFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 234A

…ls cannot be brought within the realm of the definition of „royalty‟ as provided in Article 12(3) of the IndiaCanada tax treaty. Our aforesaid view is fortified by the judgment of the Hon’ble High Court of Madhya Pradesh in the case of CIT Vs. HEG Ltd. (2003) 263 ITR 230 (MP). In the said case, it was observed by the Hon‟ble High Court that it is not any information concerning the industrial or commercial venture that could earn the status as that of International Air Transport Association (Canada) royalty, as some expertise or skill in providing of such information would be required. In this regard, it was obser…

INTERNATINAL AIR TRANSPORT ASSOCIATION (CANADA),MUMBAI vs. DCIT (IT) 2(2)(1), MUMBAI

Accordingly Ground No. 3 to 7 are allowed

ITA 7416/MUM/2017[2014-15]Status: DisposedITAT Mumbai08 Jan 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Porus Kaka, Shri DiveshFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 234A

…ls cannot be brought within the realm of the definition of „royalty‟ as provided in Article 12(3) of the IndiaCanada tax treaty. Our aforesaid view is fortified by the judgment of the Hon’ble High Court of Madhya Pradesh in the case of CIT Vs. HEG Ltd. (2003) 263 ITR 230 (MP). In the said case, it was observed by the Hon‟ble High Court that it is not any information concerning the industrial or commercial venture that could earn the status as that of International Air Transport Association (Canada) royalty, as some expertise or skill in providing of such information would be required. In this regard, it was obser…

AMERIACAN CHEMICAL SOCIETY,GURGAON vs. THE DEPUTY COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION) CIRCLE--1(1)(1), MUMBAI

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 735/MUM/2023[2020-21]Status: FixedITAT Mumbai31 Mar 2023AY 2020-21

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Paras SavlaFor Respondent: Shri Soumendu Kumar Dash
Section 139(1)Section 143(3)Section 144C(13)Section 144C(5)Section 234Section 234ASection 253(1)(d)Section 9(1)(vi)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI G.S. PANNU, PRESIDENT AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no.735/Mum./2023 (Assessment Year : 2020–21) American Chemical Society C/o Deloitte Haskings And Sells LLP 7th Floor, Building 10, Tower–B ……………. Appellant DLF Cyber City Complex, DLF City Phase–II Gurgaon 122 002 PAN – AALCA4959L v/s Dy. Commissioner of Income Tax …………….Respondent International Taxation, Circle–1(1)(1), Mumbai Assessee by : Shri Paras Savla Revenue by : Shri Soumendu Kumar Dash Date of Hearing – 21/03/2023 Date of Order – 31/03/2023 O R D E R PER BENCH…

SPRINGER NATURE CUSTOMER SERVICES CENTRE GMBH,NEW DELHI vs. JCIT, INTERNATIONALO TAXATION, CIRCLE-3(1)(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 2534/DEL/2019[2013-14]Status: DisposedITAT Delhi14 Oct 2022AY 2013-14

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2013-14] Springer Nature Customer Services Vs Jcit Centre Gmbh (Earlier Known As (International Taxation), Springer Customer Centre Gmbh), Circle-3(1)(2), 7Th Floor, Vijaya Building, New Delhi. 17-Barakhamba Road, New Delhi-110001. Pan-Aascs1092B Appellant Respondent Appellant By S/Shri Himanshu Sinha, Bhuwan Dhooper & Vibhu Gupta, Advocates Respondent By Ms. Rashmita Jha, Cit Dr Date Of Hearing 20.09.2022 Date Of Pronouncement 14.10.2022

Section 143(3)Section 234ASection 234BSection 271Section 9(1)(vi)

…ion fee does not qualify as imparting of any secret or 11 | P a g e confidential information concerning technical, industrial, commercial or scientific knowledge, experience or skill: • Elsevier BV, In re [2021] 432 ITR 251 (AAR - Mumbai) • HEG Ltd. (2003) 263 ITR 230 (MP) • Dun and Bradstreet Information Services India P. Ltd. (2012) 338 ITR 95 (Bom.) • GVK Oil & Gas Ltd. (2016) 68 taxmann.com 134 (Hyd.) • Factset Research Systems Inc. (2009) 317 ITR 169 (AAR) 3.9 Applying the same principle to the facts of the present case, it is submitted that the subscription fees collected by the Appellant is not taxa…

AMERICAN CHEMICAL SOCIETY,GURGAON vs. THE ASSTT. CIT (INTERNATIONAL TAXATION)-1(3)(2), MUMBAI

In the result, appeal by the assessee is allowed for statistical purpose

ITA 1521/MUM/2022[2018-19]Status: DisposedITAT Mumbai29 Sept 2022AY 2018-19

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Vishal KalraFor Respondent: Shri S.H. Usmani
Section 143(3)Section 144C(13)Section 253(1)(d)Section 9(1)(vi)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.1521/Mum./2022 ITA No.1520/Mum./2022 (Assessment Year : 2018–19) (Assessment Year : 2019–20) American Chemical Society C/o Deloitte Haskins & Sells LLP 7th Floor, Building–10, Tower–B ……………. Appellant DLF Cyber City Complex DLF City, Phase–II, Gurgaon 1222002 PAN – AALCA4959L v/s Deputy Commissioner of Income Tax ……………. Respondent International Taxation Circle–1(1)(1), Mumbai Assessee by : Shri Vishal Kalra Shri S.S. Tomar Revenue by : Shri S.H. Usmani…

AMERICAN CHEMICAL SOCIETY,GURGAON vs. THE ASSTT. CIT (INTERNATIONAL TAXATION)-1(3)(2), MUMBAI

In the result, appeal by the assessee is allowed for statistical purpose

ITA 1520/MUM/2022[2019-20]Status: DisposedITAT Mumbai29 Sept 2022AY 2019-20

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Vishal KalraFor Respondent: Shri S.H. Usmani
Section 143(3)Section 144C(13)Section 253(1)(d)Section 9(1)(vi)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.1521/Mum./2022 ITA No.1520/Mum./2022 (Assessment Year : 2018–19) (Assessment Year : 2019–20) American Chemical Society C/o Deloitte Haskins & Sells LLP 7th Floor, Building–10, Tower–B ……………. Appellant DLF Cyber City Complex DLF City, Phase–II, Gurgaon 1222002 PAN – AALCA4959L v/s Deputy Commissioner of Income Tax ……………. Respondent International Taxation Circle–1(1)(1), Mumbai Assessee by : Shri Vishal Kalra Shri S.S. Tomar Revenue by : Shri S.H. Usmani…

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