DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation

330 ITR 578High Court2011#933 most cited

What is DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation authority for?

Interest under Section 234B is generally not leviable on non-residents whose income is subject to tax deduction at source under Section 195, provided the non-resident assessee did not induce short or non-deduction of TDS by the payer.

115

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2025.

Also referred to as

DIT v. Jacabs Civil Incorporated · DIT v. Mitsubishi Corporation · 330 ITR 578 · Section 234B interest non-resident · Advance tax non-resident · Tax deductible at source Section 195 · Assessee role short deduction TDS · Non-liability interest Section 234B · Section 154 mistake apparent record · Rectification interest levy · Permanent establishment advance tax · Interest under section 234B

Sections most often in play

Section 147Section 148Section 154Section 195Section 207Section 208Section 209Section 210

Issues it is cited on

section 209(1)section 209section 195(1)section 195(2)section 260interest u/s 234bsection 260asection 40(a)(i)interest under section 234bsection 195permanent establishmentadvance tax

Judgments citing DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation

DEPUTY COMMISSIONER OF INCOME TAX, NOIDA vs. FORMULA ONE MARKETING II LIMITED, UNITED KINGDOM

ITA 5092/DEL/2024[2012-13]Status: DisposedITAT Delhi30 May 2025AY 2012-13

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri Hiten Thakkar, AdvFor Respondent: Shri Surender Pal Singh, CIT(DR)
Section 148Section 154Section 195Section 209Section 234ASection 234B

…on 234B of the Act in the case of a non-resident, where the income was subject to tax deduction of at source was decided by Bombay High Court in case of DIT vs. NGC Network Asia LLC (313 ITR 187) and Delhi High Court in case of CIT vs. Mitsubishi Corporation (330 ITR 578). In view of the above, the Ld. AO did not have the jurisdiction to rectify the assessment order under Section 154 of the Act. ITA No.- 5092/Del/2024 Formula One Marke"ng II Limited 8.1 The provisions of Section 154 of the Act apply only when there is a "mistake apparent from record". In the instant case, there were two favourable decisions of B…

DCIT, CIRCLE- 2, INTERNATIONAL TAXATION , DEHRADUN vs. GAIA SHIP MANAGEMENT AS, MUMBAI

In the result, both the appeals of the revenue are dismissed

ITA 5304/DEL/2018[2015-16]Status: DisposedITAT Dehradun22 Dec 2023AY 2015-16

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us(Through Video Conferencing)

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Sh. Mayank Kumar, Adit CIT DR
Section 143(3)

…e/payee/deductee has played a role in inducing non- deduction or short-deduction on the part of the payer/deductor. 3.3. Whether the Ld CIT(Appeals) has erred in failing to take note of the observations of the Hon'ble High Court in the case of M/s Mitsubishi [330 ITR 578, Del] that the role of the assessee/payee/deductee in short-deduction or non-deduction of tax needs to be ascertained before claim regarding non-liability to interest u/s 2348 of the Act is accepted, a proposition affirmed subsequently in the case of M/s Alcatel Lucent (judgment of Delhi High Court dated 7 11.2013 in ITA No. 327 & Ors of 2012) an…

DCIT, CIRCLE- 1, INTERNATIONAL TAXATION, DEHRADUN vs. GAIA SHIP MANAGEMENT AS, MUMBAI

In the result, both the appeals of the revenue are dismissed

ITA 7476/DEL/2017[2014-15]Status: DisposedITAT Dehradun22 Dec 2023AY 2014-15

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us(Through Video Conferencing)

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Sh. Mayank Kumar, Adit CIT DR
Section 143(3)

…e/payee/deductee has played a role in inducing non- deduction or short-deduction on the part of the payer/deductor. 3.3. Whether the Ld CIT(Appeals) has erred in failing to take note of the observations of the Hon'ble High Court in the case of M/s Mitsubishi [330 ITR 578, Del] that the role of the assessee/payee/deductee in short-deduction or non-deduction of tax needs to be ascertained before claim regarding non-liability to interest u/s 2348 of the Act is accepted, a proposition affirmed subsequently in the case of M/s Alcatel Lucent (judgment of Delhi High Court dated 7 11.2013 in ITA No. 327 & Ors of 2012) an…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 7922/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Jul 2022AY 2015-16

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. ACIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 7460/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Jul 2022AY 2015-16

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 55/DEL/2019[2014-15]Status: DisposedITAT Delhi27 Jul 2022AY 2014-15

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 3080/DEL/2019[2013-14]Status: DisposedITAT Delhi27 Jul 2022AY 2013-14

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 3079/DEL/2019[2007-08]Status: DisposedITAT Delhi27 Jul 2022AY 2007-08

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

ADOBE SYSTEMS SOFTWERE IRELAND LIMITED,DUBLIN 24, IRELAND vs. DCIT CIRCLE- 1(1)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 1979/DEL/2019[2013-14]Status: DisposedITAT Delhi27 Jul 2022AY 2013-14

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 1978/DEL/2019[2007-08]Status: DisposedITAT Delhi27 Jul 2022AY 2007-08

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 5029/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Jul 2022AY 2012-13

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 5028/DEL/2017[2011-12]Status: DisposedITAT Delhi27 Jul 2022AY 2011-12

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 5027/DEL/2017[2010-11]Status: DisposedITAT Delhi27 Jul 2022AY 2010-11

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 5026/DEL/2017[2006-07]Status: DisposedITAT Delhi27 Jul 2022AY 2006-07

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 5025/DEL/2017[2005-06]Status: DisposedITAT Delhi27 Jul 2022AY 2005-06

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 5024/DEL/2017[2004-05]Status: DisposedITAT Delhi27 Jul 2022AY 2004-05

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 4923/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Jul 2022AY 2012-13

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 4922/DEL/2017[2011-12]Status: DisposedITAT Delhi27 Jul 2022AY 2011-12

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

ITA 4921/DEL/2017[2010-11]Status: DisposedITAT Delhi27 Jul 2022AY 2010-11

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 9(1)(vi)

…, despite of the fact that tax was ‘deductible’ at source on the entire income earned by it in those years. • However, on the basis of the decision of the Hon’ble Delhi High Court in the case of DIT v. Jacabs Civil Incorporated/ Mitsubhishi Corporation [2011] 330 ITR 578 (Delhi), and DIT v. GE Packaged Power Inc. [2015] 373 ITR 65 (Delhi) (please refer to pages 533 to 550 of the case law compilation), the CIT(A) has held that interest under section 234B of the Act should not be applied for until AY 2012-13. Relying upon the above-mentioned judicial • precedents, it may be contended that for AY 2007-08, AY 2010-11…

SCHLUMBERGER ASIA SERVICES LTD.,GURGAON vs. DDIT, DEHRADUN

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 6437/DEL/2014[2011-12]Status: DisposedITAT Dehradun05 May 2022AY 2011-12

Bench: Shri R.K. Panda & Shri C.N. Prasad[Assessment Year: 2011-12] Schlumberger Asia Services Deputy Director Of Income Tax Limited, (International Taxation), 14Th Floor, Tower C, Building Dehradun No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan-Aadcs1107J Assessee Revenue [Assessment Year: 2011-12] Deputy Director Of Income Tax Schlumberger Asia Services (International Taxation), Limited, Dehradun 14Th Floor, Tower C, Building No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan- Aadcs1107J Revenue Assessee Assessee By Sh. Salil Kapoor, Adv. Ms. Ananya Kappor & Ms. Soumya Singh, Adv. Revenue By Sh. T.S.Mapwal, Sr.Dr

Section 143(3)Section 44BSection 44DSection 9

…resident assessee/payee/deductee has played a role in inducing non-deduction or short-deduction on the part of the payer/deductor. b. The Ld.CIT(A) has erred in failing to take note of the observations of the Hon’ble High Court in the case of M/s Mitsubishi [330 ITR 578, Del] that the role of the assessee/payee/deductee in short-deduction or non¬deduction of tax needs to be ascertained before claim regarding non¬liability to interest u/s 234B of the Act is accepted, a proposition affirmed subsequently in the case of M/s Alcatel Lucent (judgment of Delhi High Court dated 07.11.2013 in ITA No. 327 & Ors of 2012).…

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