Tej International Pvt Ltd. v. DCIT (

Genpact India Private Limited, Delhi vs. ACIT, OSD Range-10, Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalgenpact India Private Limited Vs Assessment Unit, Income 12A, Ground Floor,K Prakash Tax Department, 2Nd Floor, Deep Building 7 Tolstoy Marg, E-Ramp, Jawaharlal Nehru Baroda House, S.O. Baroda Stadium, New Delhi House, Delhi Pan: Aabce4461B Appellant Respondent Genpact India Private Limited Vs Assistant Commissioner Of 12A, Ground Floor, Prakash Income Tax (Osd), Range-10 Deep Building 7 Tolstoy Marg, Central Revenue Building, Baroda House, S.O. Baroda Ito, New Delhi-110002 House, Delhi Pan: Aabce4461B Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv (Virtual) &Ms.Vyushtirawat, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

…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…

Dnata International Private Limited, Haryana vs. DCIT, Circle 1(1), Gurgaon Or Assessment Unit, Income Tax Department, Gurgaon

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaldnata International Private Vs Deputy Commissioner Of Limited. Ground Floor, R1, R2, Income Tax, Circle 1(1), Park Centra, Sector-30, Nh-8, Gurgaon Or Assessment Unit, Gurgaon, Haryana Income Tax Department, Pan: Aadcd7460P Gurgaon, Haryana Appellant Respondent Assessee By Sh. Nikhil Tiwari, Adv (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

…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…

Signify Innovations India Limited, Haryana vs. Deputy Commissioner of Income Tax, Circle 3(1), Haryana

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalsignify Innovations India Limited Vs Deputy Commissioner Of 9B, 9Th Floor, Dlf Cyber City, Income Tax, Circle 3(1), Range Dlf Qe, S.O. Gurgaon, Haryana Code 107, Income Tax Officer, Pan: Aaicp0987G Shankar Chowk, Phase V, Udyogvihar, Sector 19, Gurugram, Haryana Appellant Respondent Assessee By Ms. Reema Grewal, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

…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…

Coim India Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 4(2), Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalcoim India Private Limited Vs Deputy Commissioner Of Shop No. 4, Ground Floor Income Tax, Income Tax Rajendrabhawan, Patel Nagar, Department, Circle 4(2), East Central Delhi, Delhi Delhi Pan: Aabcy0901A Appellant Respondent Assessee By Sh. Nikhil Aggarwal, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

…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…

Haskoningdhv Consulting Private Limited, New Delhi vs. ACIT, Circle 10(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalhaskoningdhv Consulting Vs The Assistant Commissioner Private Limited, Office No. 204, Of Income Tax, Circle 10(1), 2Nd Floor, Rs Tower, Plot No. B C. R. Building, New Delhi 358A, New No. 1267, New Ashok Nagar, Vasundhara Enclave, East Delhi Pan: Aaacm8966G Appellant Respondent Assessee By Sh. Harpreet Singh Ajmani, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

…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…

Beam Global Spirits and Wine (India) Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle 4(2), Assessment Unit, NFAC, 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 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…

Airbnb India Private Limited, Delhi, India vs. The Deputy Commissioner of Income Tax, Circle 1(1), Central Revenue Building, Delhi, India

In the result, the appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb India Private Limited, Dcit, Circle-1(1), 5Th Floor, Caddie Commercial Central Revenue Building, Tower, Aerocity, Vs. Delhi. New Delhi-110037. Pan-Aakca5525B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 24.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. & 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 27.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 24/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 537 (Madras) & Also Airbnb India Pvt. Ltd. Vs. Ito Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

…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…

Motorola Solutions India Private Limited, Gurgaon vs. Deputy Commissioner of Income Tax, Circle 1(1), Gurgaon

In the result, appeal of the Assessee is allowed

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

…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 ITA No. 4324/Del/2024 Motorola Solutions India (P) Ltd. Vs. DCIT 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…

Avaya India Private Limited, Mumbai vs. Assessing Officer, NFAC, Not Available

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…

Airbnb Payments India Private Limited, Gurugram, Haryana vs. The Deputy Commissioner of Income Tax, Circle 1(1), Gurugram, Haryana

In the result, the appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb Payments India Private Dcit, Circle-1(1), Limited, Gurugram, Haryana. Level 9, Spaze I Tech Park, Vs A1 Tower, Sector-49, . Sohna Road, Gurugram-122018 Haryana. Pan-Aanca6203B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 18.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 24.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 18/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On Airbnb Payments India Private Limited Vs. Dcit The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 Itr 537 (Madras) & Also Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

…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…

At and T Communication Services India Private Limited, New Delhi vs. Assistant Commissioner of Income Tax Circle 1(1), Office of ACIT, Cr Building, Delhi

In the result, appeal of the Assessee is 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…

Genpact India Private Limited, New Delhi vs. Assessment Unit, Income Tax Department, New Delhi

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalgenpact India Private Limited Vs Assessment Unit, Income 12A, Ground Floor,K Prakash Tax Department, 2Nd Floor, Deep Building 7 Tolstoy Marg, E-Ramp, Jawaharlal Nehru Baroda House, S.O. Baroda Stadium, New Delhi House, Delhi Pan: Aabce4461B Appellant Respondent Genpact India Private Limited Vs Assistant Commissioner Of 12A, Ground Floor, Prakash Income Tax (Osd), Range-10 Deep Building 7 Tolstoy Marg, Central Revenue Building, Baroda House, S.O. Baroda Ito, New Delhi-110002 House, Delhi Pan: Aabce4461B Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv (Virtual) &Ms.Vyushtirawat, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

…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…

Fmi Automotive Components Private Limited, Gurgaon vs. ACIT Circle 7(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…

Win Medicare Private Limited, Delhi vs. Assessment Unit, Income Tax Department (Deputy Commissioner of Income Tax Circle 25(1), 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…

Triumph Motorcycles (India) Private Limited, New Delhi vs. DCIT, Circle 25(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaltriumph Motorcycles (India) Vs The Pvt. Ltd. 2Nd Floor, Wing-A Additional/Joint/Deputy/Assista Radisson Blu Plaza, Nh-8, Nt Commissioner Of Income Tax, Mahipalpur, New Delhi Nfac, New Delhi Pan: Aaect1592M Appellant Respondent Assessee By Dr. Shaswat Bajpai, Adv (Virtual), Sh. Mayank Chaturvedi, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

…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…

Fmi Automotive Components Pvt Ltd, Gurgaon vs. ACIT, Circle 7(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…

Amplus Kn Solar Private Limited, Gurgaon vs. ITO, Ward- 2(1), Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalampluskn Solar Private Limited Vs Ito 6Th Floor, The Palm Square, Golf Ward-2(1), C. R. Building, Course Extension Road, Sector - New Delhi 66, Grugaon, Haryana Pan: Aapca3377G Appellant Respondent Assessee By Sh. Km Gupta, Adv, Ms.Shruti Khimta, Ar & Sh. Jaskaran Singh, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

…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…

Claas Agricultural Machinery Private Limited, New Delhi vs. Deputy Commissioner of Income-Tax, Circle 4(2), New Delhi

In the result, appeal of the Assessee is allowed

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

…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 ITA No. 4563/Del/2024 Class Agricultural Machinery 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…

Itron India Private Limited, Noida vs. The Assistant Commissioner of Income Tax, Circle 10(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalitron India Private Limited Vs The Assistant Commissioner C-7, Sector-3, Noida Gautam Of Income Tax, Circle 10(1), Budh Nagar, Uttar Pradesh C. R. Building, I. P. Estate, Pan: Aabcs6575L New Delhi 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 21/01/2026

…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 19 Itron India Pvt. Ltd. Vs. The ACIT 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 lib…

Xl India Business Services Private Limited, Delhi vs. The Assistant Commissioner of Income Tax, New Delhi

In the result, appeal of the Assessee is 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 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…