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“tax residency certificate”

International TaxSection 90(4)Section 90(4)328 judgments

The decision most relied on for tax residency certificate is CIT v. Kotak Securities Ltd. (340 ITR 333), cited in 161 judgments on BharatTax.

Leading authorities on tax residency certificate

CIT v. Kotak Securities Ltd.
340 ITR 333 · 2012 · High Court
161
citing judgments

A deductor's bonafide belief or reliance on a Tax Residency Certificate (TRC) can influence whether they are deemed an 'assessee in default' under Section 195 for failing to deduct tax at source on payments to non-residents. The decision clarifies the due diligence required when interpreting tax treaties and TRCs for TDS compliance.

Sanofi Pasteur Holding SA v. Department of Revenue
354 ITR 316 · 2013 · High Court
42
citing judgments

Gains from the indirect transfer of shares in a foreign company holding Indian shares are not taxable in India under the relevant tax treaty, which is considered a self-contained code to be interpreted plainly. Creating corporate structures or special purpose vehicles for investment to secure tax benefits is a legitimate business activity.

Edenred Pte. Ltd. v. Deputy Director of Income Tax (International
118 Taxmann.com 2 · 2020 · Reported
14
citing judgments

The case is authority for the proposition that where a tax treaty provides for a more beneficial treatment than the Income Tax Act, the treaty provisions will prevail, provided certain conditions under section 90(2) are met.

Judgments citing tax residency certificate

The Dy. Commr. of Income Tax, Cir.-3(1), Rajkot-Gujarat vs. M/S. Sonpal Exports Pvt. Ltd., Rajkot-Gujarat

In the result, appeal filed by the revenue is dismissed

ITA 29/RJT/2018[2012-13]Status: DisposedITAT Rajkot21 Aug 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 29/Rjt/2018 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) The Dcit, Circle – 3(1), Vs. M/S. Sonpal Exports Pvt. Ltd. Rajkot Aayakar Bhavan, Room Dhari Bagsara Road, Nr. Ice No. 114, 1St Floor, Race Course Factory, Amreli Ring Road, Rajkot Pan No.: Aajcs0177N (Assessee) (Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Praveen Verma, Ld. Cit(Dr) Date Of Hearing : 24/06/2025 Date Of Pronouncement : 21/08/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am; By Way Of This Appeal, The Revenue, Has Challenged Correctness Of The Order Dated 16.11.2017, Passed By The Learned Cit(A), In The Matter Of Assessment Under Section 143(3) Of The Income Tax Act 1961, For The Assessment Year 2012-13. Grievances Raised By The Revenue, Which Are Interconnected & Will Be Taken Up Together, Are As Follows: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 13,96,33,023/- Holding That Provision Of Section 195 Will Not Be Applicable. 2. On The Facts Of The Case & In Law, The Ld. C.I.T. (A) Erred In Ignoring The Facts That The Assessee Has Failed To Prove The Genuineness Of Foreign Commission Expenses Before The A.O. 3. It Is, Therefore, Prayed That The Order Of The C.I.T. (A) May Be Set Aside & That Of The A.O. Be Restored To The Above Extent. Dcit Vs. M/S. Sonpal Export Pvt. Ltd.

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Praveen Verma, Ld. CIT(DR)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 195

r.w.s.195 of the Act. As regards the treaty protection sought by the assessee, the Assessing Officer observed that the assessee has not furnished tax residency certificates. In any event, according to the Assessing Officer, the India Thailand and India UAE tax treaties did not have any specific clause dealing with

Jaldhi Overseas Pte. Ltd., Singapore vs. ACIT/DCIT, International Taxation-1(2), Chennai

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

ITA 366/CHNY/2025[2022-23]Status: DisposedITAT Chennai19 Aug 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.366/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 V. Jaldhi Overseas Pte. Ltd., The Assistant Commissioner Of #25-60, Tong Eng Building, 101, Cecil Income Tax, International Street, Singapore 069533. Taxation, Dcit, Intl. Tax 1(2), C/O. Bothra Shipping Services Private Chennai. Limited, Vasundhara, 9Th Floor, Unit-A, 2/7 Sarat Bose Road, L.R. Sarani S.O., Kalkata, West Bengal 700 020. [Pan: Aadcj0165F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से /Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाईकीतारीख/Date Of Hearing : 13.08.2025 घोषणाकीतारीख /Date Of Pronouncement : 19.08.2025 आदेश / O R D E R Per Manu Kumar Giri, Jm:

For Appellant: Shri Ashik Shah, C.AFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 153Section 44B

income to the residence country, which in the Appellant's case is Singapore, since Appellant is a tax resident of Singapore (Refer Tax Residency Certificate enclosed in page 14 of paper book).  In this connection, the Appellant relies upon the ruling of the Hon'ble Jurisdictional High Court

Tfdac Ireland II Limited, Ireland vs. Deputy Commissioner of Income Tax International Tax Circle 4(1)(2) Mumbai, Mumbai

ITA 1198/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23
Section 143(3)Section 144C(13)Section 144C(5)

assessee is a company incorporated on 18 April 2018 under the laws of Ireland, and is a tax resident thereof, holding valid Tax Residency Certificates (“TRCs”) issued by the Irish Revenue Authorities. It forms part of the TFDAC Group, an international aircraft leasing conglomerate consisting of four Irish entities ... were executed on 1 February 2019, prior to the introduction of the MLI. (b) The assessee holds a valid Tax Residency Certificate (“TRC”) issued by the Irish Tax Authorities. (c) The India–Ireland DTAA was entered into “for promotion of trade between India and Ireland”, and aircraft leasing

Dae(Sy22) Leasing (Ireland)41, Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax International Taxation Circle 2(1)(2), Mumbai

ITA 1157/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

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

Section 143(3)Section 144C(13)Section 144C(5)

assessee is a company incorporated on 18 April 2018 under the laws of Ireland, and is a tax resident thereof, holding valid Tax Residency Certificates (“TRCs”) issued by the Irish Revenue Authorities. It forms part of the TFDAC Group, an international aircraft leasing conglomerate consisting of four Irish entities ... were executed on 1 February 2019, prior to the introduction of the MLI. (b) The assessee holds a valid Tax Residency Certificate (“TRC”) issued by the Irish Tax Authorities. (c) The India–Ireland DTAA was entered into “for promotion of trade between India and Ireland”, and aircraft leasing

Dae (Sabs) Leasing Ireland 43 Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax Int Tax.Circle 2(1)(2), Mumbai

In the result, appeals of the assessees are allowed and

ITA 1156/MUM/2025[2022-22]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-22
Section 143(3)Section 144C(13)Section 144C(5)

assessee is a company incorporated on 18 April 2018 under the laws of Ireland, and is a tax resident thereof, holding valid Tax Residency Certificates (“TRCs”) issued by the Irish Revenue Authorities. It forms part of the TFDAC Group, an international aircraft leasing conglomerate consisting of four Irish entities ... were executed on 1 February 2019, prior to the introduction of the MLI. (b) The assessee holds a valid Tax Residency Certificate (“TRC”) issued by the Irish Tax Authorities. (c) The India–Ireland DTAA was entered into “for promotion of trade between India and Ireland”, and aircraft leasing

Dae (Sabs) 10296 Ireland Designated Activity Company, Mumbai vs. Assistant Commissioner of Income Tax (Int Taxation), Cirlce 2(1)(2), Mumbai

In the result, appeals of the assessees are allowed and

ITA 1155/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23
Section 143(3)Section 144C(13)Section 144C(5)

assessee is a company incorporated on 18 April 2018 under the laws of Ireland, and is a tax resident thereof, holding valid Tax Residency Certificates (“TRCs”) issued by the Irish Revenue Authorities. It forms part of the TFDAC Group, an international aircraft leasing conglomerate consisting of four Irish entities ... were executed on 1 February 2019, prior to the introduction of the MLI. (b) The assessee holds a valid Tax Residency Certificate (“TRC”) issued by the Irish Tax Authorities. (c) The India–Ireland DTAA was entered into “for promotion of trade between India and Ireland”, and aircraft leasing

Sky High Xliii Leasing Company Limited, Ireland vs. Assistant Commissioner of Income Tax Int Tax Circle 4 (2) (1) Mumbai, Mumbai

ITA 1122/MUM/2025[2022-2023]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-2023
Section 143(3)Section 144C(13)Section 144C(5)

assessee is a company incorporated on 18 April 2018 under the laws of Ireland, and is a tax resident thereof, holding valid Tax Residency Certificates (“TRCs”) issued by the Irish Revenue Authorities. It forms part of the TFDAC Group, an international aircraft leasing conglomerate consisting of four Irish entities ... executed on 1 February 2019, prior to the introduction of the MLI. 15 ITA No.1198/Mum/2025 and others (b) The assessee holds a valid Tax Residency Certificate (“TRC”) issued by the Irish Tax Authorities. (c) The India–Ireland DTAA was entered into “for promotion of trade between India and Ireland

Ortus Aircraft Lease 5( Dublin) Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(2) International Taxation, Mumbai

ITA 1108/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

assessee is a company incorporated on 18 April 2018 under the laws of Ireland, and is a tax resident thereof, holding valid Tax Residency Certificates (“TRCs”) issued by the Irish Revenue Authorities. It forms part of the TFDAC Group, an international aircraft leasing conglomerate consisting of four Irish entities ... were executed on 1 February 2019, prior to the introduction of the MLI. (b) The assessee holds a valid Tax Residency Certificate (“TRC”) issued by the Irish Tax Authorities. (c) The India–Ireland DTAA was entered into “for promotion of trade between India and Ireland”, and aircraft leasing

Ortus Aircraft Lease 6(Dublin) Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(2) International Taxation, Mumbai

ITA 1106/MUM/2025[2022-23]Status: DisposedITAT Mumbai13 Aug 2025AY 2022-23

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

Section 143(3)Section 144C(13)Section 144C(5)

assessee is a company incorporated on 18 April 2018 under the laws of Ireland, and is a tax resident thereof, holding valid Tax Residency Certificates (“TRCs”) issued by the Irish Revenue Authorities. It forms part of the TFDAC Group, an international aircraft leasing conglomerate consisting of four Irish entities ... were executed on 1 February 2019, prior to the introduction of the MLI. (b) The assessee holds a valid Tax Residency Certificate (“TRC”) issued by the Irish Tax Authorities. (c) The India–Ireland DTAA was entered into “for promotion of trade between India and Ireland”, and aircraft leasing

Sanjiv Soshil Mehta, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 5(2), Kautilya Bhavan

In the result, appeal of the assessee is allowed

ITA 2096/MUM/2025[2020-2021]Status: DisposedITAT Mumbai23 Jul 2025AY 2020-2021

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Revenue byFor Respondent: Income-tax – 1, Mumbai
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 263Section 90

Please also furnish the calculation the relief claimed u/s 90/91 during the year. ii. Detailed note on the basis of relief claimed. iii. Tax Residency Certificate in case of Non-Resident. iv. Details of taxes paid outside India on the income accrue or arise outside India with documentary evidence

Sivakarthick Raman, Madurai vs. The Assistant Commissioner of Income Tax, International Taxation, Circle Madurai

In the result, the appeal of the assessee is allowed in terms of our above order

ITA 281/CHNY/2025[2022-23]Status: DisposedITAT Chennai07 Jul 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:281/Chny/2025 िनधा"रण वष" / Assessment Year: 2022-23 Sivakarthick Raman, The Assistant Commissioner Of 5/200, 2Nd Street, Alagupillai Nagar, Vs. Income Tax, T.Pudukudi, International Taxation Circle, Achampathu, Madurai. Madurai – 625 019. [Pan: Ajnpr-3214-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Preeti Goel, Advocate ""थ" की ओर से/Respondent By : Ms. Anitha, Addl. C.I.T. सुनवाई की तारीख/Date Of Hearing : 21.04.2025 घोषणा की तारीख/Date Of Pronouncement : 07.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

For Appellant: Ms. Preeti Goel, AdvocateFor Respondent: Ms. Anitha, Addl. C.I.T
Section 143(3)Section 144C(13)Section 15Section 15(1)(a)Section 234BSection 234DSection 5(2)Section 5(2)(a)Section 9(1)(ii)Section 90

281/Chny/2025 3. The learned DRP has in the facts and circumstances of the case and in law erred in holding that the tax residency certificate was not filed by the Appellant while ignoring that the China Tax Return was sufficient evidence of Residency in China. 4. Without prejudice, the learned ... assessee. k) The learned DRP has in the facts and circumstances of the case and in law erred in holding that the tax residency certificate was not filed by the assessee while ignoring that the China Tax Return was sufficient evidence of Residency in China Ground 4 13. Without prejudice

DCIT(It)-3(2)(2), Mumbai vs. Murex Southeast Asia Private Limited, Singapore

The appeal of the Revenue is dismissed

ITA 1453/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jun 2025AY 2014-15

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 250Section 271(1)(c)

financial sector and providing related maintenance other support and training services with respective such software sub-licensed by its. The assessee holds valid Tax Residency Certificate (TRC) obtained from the authorities in Singapore. During the year under consideration the assessee had receipts to the tune of Rs.31

Mr. 3 Sigma Global Fund, Mumbai vs. Assistant Commissioner of Income Tax Int Tax Circle 4(2)(1), Mumbai

Accordingly we hold that the gain arising from the transfer of Derivatives cannot be taxed in India and the addition made in this regard stands deleted. Ground No. 1 raised by the assessee is hereb...

ITA 1130/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jun 2025AY 2022-23

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Bhaumik Goda, ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)

laws of Republic of Mauritius and holds global business licence issued by Financial Service Commission in Mauritius. The assessee also holds a tax residence certificate issued by Mauritius Revenue Authority. The assessee for the year under consideration filed the return of income on 29.10.2022 declaring total income ... Company (FPI) does not meet the standard for rejection of Treaty benefits. Panel is in complete agreement with the Assessing Officer that the Tax Residence Certificate (TRC) issued by a low-tax jurisdiction is not the sole instrument for availment of Treaty benefits. However, it was incumbent on the Assessing

Essar Communications Limited, Mauritius vs. ACIT, Circle-1 (2)(2), New Delhi

ITA 340/DEL/2022[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri N. Venkatraman, ASG
Section 250Section 253Section 6(3)

sale of VEL shares by the Appellant to EPSL; 7. erred in ignoring the facts that the Appellant was incorporated in Mauritius, holds tax residence certificates, global business license etc and that the Appellant was entitled to the benefits of Article 13(4) of the tax treaty; 8. erred ... incorporated in Mauritius on 13 October 2005. The principal activity of the Assessee is to make and hold investments. The Assessee holds valid Tax Residency Certificates (‘TRC’) issued by the Mauritius Revenue Authority (‘MRA’) and Category 1 Global Business License (‘GBL’) issued by the Financial Services Commission, Mauritius since inception

Essar Com Limited, Mauritius vs. ACIT, Circle 1(2)(2), New Delhi

ITA 339/DEL/2022[2012-13]Status: DisposedITAT Delhi30 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shris.Rifaur Rahman

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri N. Venkatraman, ASG
Section 250Section 253Section 6(3)

sale of VEL shares by the Appellant to EPSL; erred in ignoring the facts that the Appellant was incorporated in Mauritius, holds tax residence certificates, global business license etc and that the Appellant was entitled to the benefits of Article 13(4) of the tax treaty; erred in disregarding settled ... incorporated in Mauritius on 13 October 2005. The principal activity of the Assessee is to make and hold investments. The Assessee holds valid Tax Residency Certificates (‘TRC’) issued by the Mauritius Revenue Authority (“MRA’) and Category 1 Global Business License (‘GBL’) issued by the Financial Services Commission, Mauritius since inception

Amplus Energy Solutions Pte Ltd, Malaysia vs. Assistant Commissioner of Income Tax, Circle International Tax 1(1)(1), Civic Center, Delhi

ITA 3370/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi25 Jun 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 115A(1)(a)Section 143(3)Section 144CSection 194L

before us are that the Appellant is a foreign company and is tax resident of Singapore during the year under consideration. Copy of Tax Residency Certificate issued by the Inland Revenue Authority of Singapore is filed in paper book at page no. 1 to 3. The Company is a Category

Amplus Energy Solutions Pte Ltd, Singapore vs. The Office of the Assistant Commissioner of Income Tax, New Delhi

ITA 2417/DEL/2023[2020-21]Status: DisposedITAT Delhi25 Jun 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2020-21 Amplus Energy Solutions Pte Vs Acit, Ltd., Circle International Tax 1(1)(1), #02-00, Robinson Road, New Delhi. Singapore – 688898 Pan: Aadci8182P Assessment Year: 2021-22 Amplus Energy Solutions Pte Vs. Acit, Ltd., Malaysia, Circle International Tax 1(1)(1), Level 56, Tower-1, Petronas New Delhi. Twin Towers, Kuala Lumpur City Centre, 50088, Kuala Lumpur, Malaysia/ 6Th Floor, Emaar Mgf, The Palm Square, Golf Course Ext. Road, Sector-66, Gurgaon – 122 102. Pan: Aadci8182P (Appellant) (Respondent) Assessee By : Shri K.M. Gupta, Advocate & Ms Shruti Khimta, Ar Revenue By : Ms Ekta Jain, Cit-Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 25.06.2025

For Appellant: Shri K.M. Gupta, Advocate &For Respondent: Ms Ekta Jain, CIT-DR
Section 115ASection 115A(1)(a)Section 143(3)Section 144CSection 194LSection 3

before us are that the Appellant is a foreign company and is tax resident of Singapore during the year under consideration. Copy of Tax Residency Certificate issued by the Inland Revenue Authority of Singapore is filed in paper book at page no. 1 to 3. The Company is a Category

ACIT, Circle-4(2), New Delhi vs. Bharti Airtel Ltd., New Delhi

The appeal of the Revenue is partly allowed and appeal of the assessee is allowed

ITA 6079/DEL/2019[2008-09]Status: DisposedITAT Delhi09 Jun 2025AY 2008-09

Bench: Shri Vikas Awasthy& Shri Amitabh Shuklaआअसं.5692 और5693/दिल्ली/2019 (नि.व. 2007-08 और2008-09)

For Appellant: S/Shri Rohit Jain, Deepesh Jain, Advocates andFor Respondent: Shri Javed Akhtar, CIT(DR)
Section 195Section 40

Interest paid to ABN Amro Total Rs.62,47,96,308/- Rs.25,35,96,279/- Rs.87,83,92,587/- Since ABN Amro had furnished Tax Residency Certificate (TRC) issued by Swedish Tax Authority (at page 159-160 of the paper book), the assessee on the 5 ITA Nos.5962 &6078/Del/2019 ... tax resident of Sweden. In proceedings u/s.201 of the Act, the Department wrote to Swedish Tax Authorities regarding genuineness of Tax Residency Certificate. In response to the query raised by the Indian Tax Authorities, it was confirmed by the Swedish Tax Agency that the certificate was authentic and was made

ACIT, Circle-4(2), New Delhi vs. Bharti Airtel Ltd., New Delhi

The appeal of the Revenue is partly allowed and appeal of the assessee is allowed

ITA 6078/DEL/2019[2007-08]Status: DisposedITAT Delhi09 Jun 2025AY 2007-08

Bench: Shri Vikas Awasthy& Shri Amitabh Shuklaआअसं.5692 और5693/दिल्ली/2019 (नि.व. 2007-08 और2008-09)

For Appellant: S/Shri Rohit Jain, Deepesh Jain, Advocates andFor Respondent: Shri Javed Akhtar, CIT(DR)
Section 195Section 40

Rs.62,47,96,308/- Interest paid to ABN Amro : Rs.25,35,96,279/- Total Rs.87,83,92,587/- Since ABN Amro had furnished Tax Residency Certificate (TRC) issued by Swedish Tax Authority (at page 159-160 of the paper book), the assessee on the 5 ITA Nos.5962 &6078/Del/2019

Bharti Airtel Limited, New Delhi vs. ACIT Circle 4(2), New Delhi

The appeal of the Revenue is partly allowed and appeal of the assessee is allowed

ITA 5963/DEL/2019[2008-09]Status: DisposedITAT Delhi09 Jun 2025AY 2008-09

Bench: Shri Vikas Awasthy& Shri Amitabh Shuklaआअसं.5692 और5693/िद"ी /2019(िन.व. 2007-08 और2008-09)

For Appellant: S/Shri Rohit Jain, Deepesh Jain, Advocates and Shri Shivam Gupta, Chartered AccoFor Respondent: Shri Javed Akhtar, CIT(DR)
Section 195Section 40

Rs.62,47,96,308/- Interest paid to ABN Amro : Rs.25,35,96,279/- Total Rs.87,83,92,587/- Since ABN Amro had furnished Tax Residency Certificate (TRC) issued by Swedish Tax Authority (at page 159-160 of the paper book), the assessee on the 5 ITA Nos. 5962 &6078/Del/2019