Keshavji Ravji and Co. v. CIT

82 ITR 913Supreme Court of India1971#431 most cited
209

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2000 to 2025.

Also referred to as

Keshavji Ravji and Co. v. CIT · Section 269SS penalty · Section 269T penalty · Section 271D penalty · Section 271E penalty · cash transactions penalty · literal interpretation tax law · legislative intent tax · income deemed assessee's · definition of relative

Also reported as

49 Taxmann 87

Sections most often in play

Section 143(3)Section 153ASection 131(1A)Section 132ASection 269SSSection 269TSection 271DSection 271E

Issues it is cited on

section 5(8)closely held companyprincipal director general of income-taxaccumulated profitssection 292bsection 292bbsection 260section 260asection 282section 292section 119section 29

Judgments citing Keshavji Ravji and Co. v. CIT

Sad Bhawna, Delhi vs. DCIT, Central Circle-6, New Delhi

In the result, the six quantum appeals and six penalty appeals of the assessee for AYs 2007-08, 2008-09, 2009-10, 2010-11, 2012-13, 2013-14 are allowed

ITA 2948/DEL/2022[2010-11]Status: DisposedITAT Delhi12 Dec 2023AY 2010-11

Bench: Shri M. Balaganesh & Ms. Astha Chandra

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 254

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Javeri…

Sad Bhawna, Delhi vs. DCIT, Central Circle-6, New Delhi

In the result, the six quantum appeals and six penalty appeals of the assessee for AYs 2007-08, 2008-09, 2009-10, 2010-11, 2012-13, 2013-14 are allowed

ITA 2947/DEL/2022[2009-10]Status: DisposedITAT Delhi12 Dec 2023AY 2009-10

Bench: Shri M. Balaganesh & Ms. Astha Chandra

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 254

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Javeri…

Sad Bhawna, Delhi vs. DCIT, Central Circle-6, New Delhi

In the result, the six quantum appeals and six penalty appeals of the assessee for AYs 2007-08, 2008-09, 2009-10, 2010-11, 2012-13, 2013-14 are allowed

ITA 2946/DEL/2022[2008-09]Status: DisposedITAT Delhi12 Dec 2023AY 2008-09

Bench: Shri M. Balaganesh & Ms. Astha Chandra

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 254

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Javeri…

Sad Bhawna, Delhi vs. DCIT, Central Circle-6, New Delhi

In the result, the six quantum appeals and six penalty appeals of the assessee for AYs 2007-08, 2008-09, 2009-10, 2010-11, 2012-13, 2013-14 are allowed

ITA 2945/DEL/2022[2007-08]Status: DisposedITAT Delhi12 Dec 2023AY 2007-08

Bench: Shri M. Balaganesh & Ms. Astha Chandra

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri H.K. Choudhary, CIT-DR
Section 254

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Javeri…

Dragon Foods Pvt Ltd., New Delhi vs. ACIT Central Circle-14, New Delhi

In the result, all the appeals are allowed

ITA 234/DEL/2023[2017-18]Status: DisposedITAT Delhi05 Dec 2023AY 2017-18

Bench: Sh. N. K. Billaiya & Ms. Astha Chandra

Section 119Section 153CSection 153D

…y refunded to the companies they would not be taken into account under Section 12(1-8)," Sections 2(6-4)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case ((1972) 4 SCC 474 1974 SCC (Tax) 304 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: "Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C Javeri…

Dragon Foods Pvt Ltd., New Delhi vs. ACIT Central Circle-14, New Delhi

In the result, all the appeals are allowed

ITA 233/DEL/2023[2016-17]Status: DisposedITAT Delhi05 Dec 2023AY 2016-17

Bench: Sh. N. K. Billaiya & Ms. Astha Chandra

Section 119Section 153CSection 153D

…y refunded to the companies they would not be taken into account under Section 12(1-8)," Sections 2(6-4)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case ((1972) 4 SCC 474 1974 SCC (Tax) 304 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: "Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C Javeri…

Dragon Foods Pvt Ltd., New Delhi vs. ACIT Central Circle-14, New Delhi

In the result, all the appeals are allowed

ITA 232/DEL/2023[2015-16]Status: DisposedITAT Delhi05 Dec 2023AY 2015-16

Bench: Sh. N. K. Billaiya & Ms. Astha Chandra

Section 119Section 153CSection 153D

…y refunded to the companies they would not be taken into account under Section 12(1-8)," Sections 2(6-4)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case ((1972) 4 SCC 474 1974 SCC (Tax) 304 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: "Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C Javeri…

Dragon Foods Pvt. Ltd., New Delhi vs. ACIT Central Circle-14, New Delhi

In the result, all the appeals are allowed

ITA 231/DEL/2023[2014-15]Status: DisposedITAT Delhi05 Dec 2023AY 2014-15

Bench: Sh. N. K. Billaiya & Ms. Astha Chandra

Section 119Section 153CSection 153D

…y refunded to the companies they would not be taken into account under Section 12(1-8)," Sections 2(6-4)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case ((1972) 4 SCC 474 1974 SCC (Tax) 304 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: "Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C Javeri…

Dragon Foods Pvt Ltd., New Delhi vs. ACIT Central Circle-14, New Delhi

In the result, all the appeals are allowed

ITA 230/DEL/2023[2013-14]Status: DisposedITAT Delhi05 Dec 2023AY 2013-14

Bench: Sh. N. K. Billaiya & Ms. Astha Chandra

Section 119Section 153CSection 153D

…y refunded to the companies they would not be taken into account under Section 12(1-8)," Sections 2(6-4)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case ((1972) 4 SCC 474 1974 SCC (Tax) 304 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: "Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C Javeri…

Harjeet Singh, Faridabad vs. ACIT, Central Circle-31, New Delhi

In the result, appeal filed by the assessee is allowed as

ITA 2030/DEL/2022[2015-16]Status: DisposedITAT Delhi05 Dec 2023AY 2015-16

Bench: Shri Shamim Yahya & Shri Kul Bharatharjeet Singh, Acit, Central Circle 31, House No.22, New Delhi. Mandkola The Hatin, Vs Faridabad – 121 004 Haryana. (Pan : Bpips2997Q) Appellant Respondent

For Appellant: Sh. Ved Jain, Adv. and Sh. Aman Garg, CAFor Respondent: Shri T. James Singson, CIT
Section 143(3)

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Javeri…

Pratap Singh Yadav, Haryana vs. DCIT, Central Circle-7 Delhi, Delhi

In the result, appeal of the assessee is allowed

ITA 1897/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Nov 2023AY 2015-16

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2015-16

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri P.N. Barnwal, CIT-DR
Section 153CSection 60ASection 69C

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in 10 Navnitlal C. Jav…

Cummins Technologies India (P) Ltd., Dewas vs. ACIT Circle 1(1), Ujjain

In the result, the appeal of the assesse is allowed

ITA 982/IND/2019[2015-16]Status: DisposedITAT Indore30 Nov 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

Section 143(3)Section 144CSection 144C(5)

…d by taking recourse to Section 292B of the Act. 11.2 In support of his plea that the 2019 Circular is binding on the revenue, Mr Vohra has relied on the following judgments: i. UCO Bank v. CIT, [1999] 237 ITR 889 (SC); ii. Ellerman Lines Ltd. v. CIT, [1971] 182 ITR 913 (SC); and iii. DCIT v. Sunita Finlease Ltd., [2011] 330 ITR 491 11.3 Furthermore, to back his contention that recourse cannot be taken to the provisions of Section 292B of the Act, reliance is placed on the following judgments: i. PCIT v. Maruti Suzuki India Ltd. v. CIT, ITA No. 475 of 2011 (Del); and ii. Spice Entertainment Ltd. v. CIT, ITA No. 4…

Harjeet Singh, Haryana vs. DCIT, Central Circle-31, New Delhi

In the result, appeal filed by the assessee is allowed as indicated

ITA 2031/DEL/2022[2018-19]Status: DisposedITAT Delhi20 Nov 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Kul Bharatharjeet Singh, Vs. Dcit, Central Circle 31, House No.22, Mandkola The Hatin, New Delhi. Faridabad – 121 004 (Haryana).

For Appellant: Shri Aman Garg, CAFor Respondent: Shri T. James Singson, CIT DR
Section 119Section 131Section 133

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: 9 “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Jav…

Meena Gupta, Delhi vs. DCIT, Central Circle-14, New Delhi

In the result, appeal filed by the assessee is allowed as indicated

ITA 1194/DEL/2020[2011-12]Status: DisposedITAT Delhi15 Nov 2023AY 2011-12

Bench: Shri Shamim Yahya & Shri Kul Bharatmeena Gupta, Vs. Dcit, Central Circle 14, C/O Bk Kapur & Company, Ca, New Delhi. Navyug Market, Ghaziabad – 201 001 (Uttar Pradesh).

For Appellant: Shri Madhav Kapoor, AdvocateFor Respondent: Ms. Nimisha Singh, CIT DR
Section 119Section 131Section 133

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on 9 which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Jave…

Tregarron Limited, England vs. ACIT Circle International Tax 3(1)(2), New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 308/DEL/2023[2016-17]Status: DisposedITAT Delhi09 Nov 2023AY 2016-17

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Rajan Vora, CAFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI KUL BHARAT, JUDICIAL MEMBER ITA No.308/Del/2023 (Assessment Year: 2016-17) Tregarron Limited, vs. ACIT, Circle, Unit 4, Eastborough Fields, International Taxation, Hemdale Business Park, Nuneaton, New Delhi. Warwickshire, England. (PAN : AAECT9686Q) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Rajan Vora, CA REVENUE BY : Shri Vizay B. Vasanta, CIT DR Date of Hearing : 02.11.2023 Date of Order : 09.11.2023 ORDER PER BENCH : These appeals by the assessee are directed against the respective order…

Tregarron Limited, England vs. ACIT Circle International Tax 3(1)(2), New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 307/DEL/2023[2015-16]Status: DisposedITAT Delhi09 Nov 2023AY 2015-16

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Rajan Vora, CAFor Respondent: Shri Vizay B. Vasanta, CIT DR
Section 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI KUL BHARAT, JUDICIAL MEMBER ITA No.308/Del/2023 (Assessment Year: 2016-17) Tregarron Limited, vs. ACIT, Circle, Unit 4, Eastborough Fields, International Taxation, Hemdale Business Park, Nuneaton, New Delhi. Warwickshire, England. (PAN : AAECT9686Q) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Rajan Vora, CA REVENUE BY : Shri Vizay B. Vasanta, CIT DR Date of Hearing : 02.11.2023 Date of Order : 09.11.2023 ORDER PER BENCH : These appeals by the assessee are directed against the respective order…

Zebra Technologies Asia Pacific Pte Ltd, Bangaluru vs. Dcitcircle Int.Taxation Tax 3(1)(1), Delhi

In the result, both the appeals filed by the assessee are allowed as

ITA 1972/DEL/2022[2019-20]Status: DisposedITAT Delhi09 Nov 2023AY 2019-20

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI KUL BHARAT, JUDICIAL MEMBER ITA No.1972/Del/2022 (Assessment Year: 2019-20) Zebra Technologies Asia Pacific Pte Ltd., vs. DCIT, Circle, C/o Symbol Technologies India Pvt. Ltd., International Taxation 3(1)(1), Block 3B, 1st, 4th & 5th Floor, New Delhi. RMZ Ecospace, Sarjapur Outer Ringh Road, Devarabisanahalli, Bangaore – 560 103 (Karnataka). (PAN : AAIFG2692J) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Ravi Sharma, Advocate REVENUE BY : Shri Vijay B. Vasanta, CIT DR Date of Hearing : 02.11.202…

Zebra Technologies Asia Pacific Pte Ltd, Bangaluru vs. DCIT, Circle Int.Taxation-3(1)(1)., New Delhi

In the result, both the appeals filed by the assessee are allowed as

ITA 1971/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Nov 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI KUL BHARAT, JUDICIAL MEMBER ITA No.1972/Del/2022 (Assessment Year: 2019-20) Zebra Technologies Asia Pacific Pte Ltd., vs. DCIT, Circle, C/o Symbol Technologies India Pvt. Ltd., International Taxation 3(1)(1), Block 3B, 1st, 4th & 5th Floor, New Delhi. RMZ Ecospace, Sarjapur Outer Ringh Road, Devarabisanahalli, Bangaore – 560 103 (Karnataka). (PAN : AAIFG2692J) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Ravi Sharma, Advocate REVENUE BY : Shri Vijay B. Vasanta, CIT DR Date of Hearing : 02.11.202…

Tableau International Unlimited Company the Oval Shelbourne Road Ballsbridge Dublin, Ireland Do4E7K5, Delhi vs. DCIT, Circle 3(1)(1) Int Taxation, Delhi

In the result, appeal filed by the assessee is allowed as indicated

ITA 1874/DEL/2022[2018-19]Status: DisposedITAT Delhi07 Nov 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Kul Bharattableau International Unlimited Company, Vs. Dcit, Circle 3(1)(1), C/O Mnk & Associate Company Secretaries, International Taxation, G – 41, Ground Floor, Delhi. West Patel Nagar, New Delhi – 110 008. (Pan : Aaect8018J) (Appellant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate Ms. Shruti Khimta, Ar Revenue By : Shri Vijay B. Vasanta, Cit Dr

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 143Section 144CSection 144C(5)

…nded to the companies they would not he taken into account under Section 12(1 -B), ” Sections 2(6-A)(e) and 12(1-B) did not suffer from the vice of unconstitutionality. This decision was followed in Ellerman Lines case [(1972) 4 SCC 474 : 1974 SCC (Tax) 304 : 82 ITR 913] where referring to another circular issued by the Central Board of Revenue under Section 5(8) of the Indian Income Tax Act, 1922 on which reliance was placed on behalf of the assessee, this Court observed: “Now, coming to the question as to the effect of instructions issued under Section 5(8) of the Act, this Court observed in Navnitlal C. Javeri…

Innio Jenbacher Gmbh & Co Og (Formerly Known As Ge Jenbacher Gmbh & Co Ohg), Austria vs. ACIT, Circle-1(3)(1), Int. Taxation, New Delhi

In the result, all the appeals filed by the assessee are allowed as

ITA 920/DEL/2023[2013-14]Status: DisposedITAT Delhi06 Nov 2023AY 2013-14

Bench: Shri Shamim Yahya & Shri Kul Bharat

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 144CSection 144C(5)Section 147

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI KUL BHARAT, JUDICIAL MEMBER ITA No.762/Del/2023 (Assessment Year: 2015-16) ITA No.764/Del/2023 (Assessment Year: 2017-18) Innio Jenbacher GmbH & Co. OG, Austria vs. ACIT, Circle 1(3)(1), C/o Plot No.1-14, Tower-5, Jaypee Wishtown, International Taxation, Sector 128, New Delhi. Noida – 201 304 (Uttar Pradesh). (PAN : AAIFG2692J) Innio Jenbacher GmbH & Co. OG, Austria vs. ACIT, Circle 1(3)(1), (formerly known as GE Jenbacher GmbH & International Taxation, Co. OHG), New Delhi. C/o Plot No.1-14, Tow…