Tej International Pvt Ltd. v. DCIT (

RENEW WIND ENERGY (RAJKOT) PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 19(1), DELHI

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

RENEW WIND ENERGY (SHIVPUR) PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 19(1), DELHI

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

JOHNSON MATTHEY INDIA PVT. LTD.,NEW DELHI vs. ACIT CIRCLE 13(1), , NEW DELHI

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaljohnson Matthey India P. Ltd. Vs The Deputy Commissioner Of C/O. Luthra & Luthra Law Income Tax, Circle 13(2) Office India, 103, Ashoka Estate, Spm Civic Centre, New Delhi Barakhamba Road, New Delhi Pan: Aaacj2919A Appellant Respondent Johnson Matthey India P. Ltd. Vs National Faceless Appeal 5Th Floor, C/O Regus Business Centre, Income Tax Center, Gurgaon, Road, South Department West Delhi Pan: Aaacj2919A Appellant Respondent Assessee By Sh. Sumit Mangal, Adv, Ms. Radhika Sharma, Adv& Ms. Soumya Pandey, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

VATIKA SEVEN ELEMENTS PVT. LTD. ,NEW DELHI vs. ACIT CIRCLE 25(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member [Assessment Year: 2018-19]

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

ITRON INDIA P.LTD,DELHI vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalitron India P. Ltd. Vs The Deputy Commissioner Of Flat No. 507, Income Tax, Circle 10(1), Bhikajicamabhawan, C. R. Building, New Delhi Bhikajicama Place, New Delhi Pan: Aabcs6575L Appellant Respondent Assessee By Sh.Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 29/01/2026

…icial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 19 Itron India Pvt. Ltd. Vs. DCIT Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

LS CABLE INDIA P.LTD.,REWARI vs. ADDL.CIT, SPECIAL RANGE-5, NEW DELHI

In the result, appeals of the Assessee in ITA No

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

LS CABLE INDIA PVT. LTD.,HARYANA vs. ACIT, NEW DELHI

In the result, appeals of the Assessee in ITA No

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

HONDA TRADING ASIA COMPANY LIMITED,THAILAND vs. DCIT, INT. TAXATION, NOIDA

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

BENTLEY SYSTEMS INDIA PRIVATE LIMITED,DELHI vs. DCIT, CIRCLE 4(2), DELHI ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbentley Systems India Private V Deputy Commissioner Of Limited. Work Well Suites, 10 Floor, S Income Tax, Circle 4(2), C. Max House, 1516/338,339 340 R. Building, Assessment Village Behapur Adjacent Okhla Unit, Income Tax Railway Station, Okhla Industrial Department, Delhi Estate, S.O. Tehkhand, South East Delhi, Delhi, 110020 Pan: Aabcb5645E Appellant Respondent Assessee By Sh. Nishank Vashistha, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

VIVO MOBILE INDIA PRIVATE LIMITED,HARYANA, INDIA vs. ASSISTANCE COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DELHI

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

TS TECH SUN INDIA PRIVATE LIMITED ,NEW DELHI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 25(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalts Tech Sun India Private Vs The Assistant Commissioner Limited, A-47, Lower Ground Of Income Tax, Circle 25(1), C. Floor, Hauz Khas, New Delhi- R. Building, I. P. Estate, 110016 Delhi-110002, New Delhi Pan: Aaact4324M Appellant Respondent Assessee By Sh. Ankit Sahni, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

JUBILANT GENERICS LIMITED,GAUTAM BUDDHA NAGAR vs. ASSESSMENT UNIT, DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaljubilant Generics Limited Vs Assessment Unit, Income Tax Plot 1A, Sector-16A Noida H. O. Department, Gautam Buddha Nagar, 201301, Delhi Uttar Pradesh Pan: Aadcj2401L Appellant Respondent Assessee By Ms. Nidhi, Ar (Virutal) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

TOYO INK INDIA PRIVATE LIMITED,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaltoyo Ink India Private Limited Vs The Deputy Commissioner Of C-151, Naraina Industrial Area, Income Tax, Circle 25(1), Phase-1, Naraina Industrial Range 46, C. R. Building, Estate, South West, Delhi- Delhi-110002, Delhi 110028Pan: Aacct5137A Appellant Respondent Assessee By Sh. Ankitsahni, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

HONDA ACCESS INDIA PRIVATE LIMITED,NOIDA, UTTAR PRADESH vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, GB NAGAR, NOIDA, UTTAR PRADESH

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalhonda Access India Private Vs Assessment Unit, Income Limited Plot No. 1-D/5, Tax Department, Circle Udyogvihar, Ecotech-Ii, Alpha 5(1)(1), G B Nagar, Nodia, Greater Noida, Gautam Uttar Pradesh Buddha Nagar, 201308, Uttar Pradesh Pan: Aacch9695K Appellant Respondent Assessee By Sh. Nishank Vashistha, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

ADIDAS INDIA MARKETING PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), DELHI, DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaladidas India Marketing Private Vs Assistant Commissioner Of Limited. Office No. 6, 2Nd Floor, Income Tax, Circle 1(1), C. R. Sector B Pocket No. 7 Plot No.11, Building, Delhi Vasantkunj South West Delhi Pan: Aaaca5313P Appellant Respondent Assessee By Sh. Ankit Sahni, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

BEUMER INDIA P.LTD,NEW DELHI vs. DCIT, CIRCLE 1(1)(2) , NEW DELHI

In the result, Appeal of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

EVERSUB INDIA PRIVATE LTD. (FORMELY AS ' SUBWAY SYSTEMS INDIA PRIVATE LTD. ,HARYANA vs. DCIT CIRCLE 22(2), DELHI

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

MSD PHARMACEUTICALS PVT LTD,DELHI vs. DCIT CIRCLE -16(1), NEW DELHI

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

BEUMER INDIA P.LTD,NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Тахтап 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…

VIVO MOBILE INDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-25(1), DELHI

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

…rtant to note that once a higher judicial forum takes a decision one way or the other, all the decisions of the Tribunal, whether division benches or special benches, cease to be relevant. In the case of Tej International Pvt Ltd Vs DCIT (118 Taxman 59 (Mag)/ 69 TTJ 650), a coordinate bench has, on this issue, observed that "In the hierarchical judicial system that we have, better wisdom of the Court below has to yield to higher wisdom of the Court above and, therefore, one a authority higher than this Tribunal has expressed an opinion on that issue, we are no longer at liberty to rely upon earlier decisions of t…