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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

AIRBNB INDIA PRIVATE LIMITED,DELHI, INDIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), CENTRAL REVENUE BUILDING, DELHI, 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.

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

AIRBNB PAYMENTS INDIA PRIVATE LIMITED,GURUGRAM, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), GURUGRAM, HARYANA, 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.

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub- section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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]

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

M/S. ORACLE INDIA PRIVATE LIMITED,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, appeals of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as Oracal India Vs. Addl. CIT and when such order

BAXTER (INDIA) PVT. LTD. ,GURGAON vs. DCIT CIRCLE-4(2), DELHI

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

ORACLE INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeals of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as Oracal India Vs. Addl. CIT and when such order

DCIT, NEW DELHI vs. M/S. ORACLE INDIA PVT. LTD., NEW DELHI

In the result, appeals of the Assessee in ITA No

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaloracle India Private Limited Vs Addl. Cit F-01/02, 1St Floor, Salcon Range-13 Rasvilas, D-1, District Centre, New Delhi Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Oracle India Private Limited Vs Dcit F-01/02, 1St Floor, Circle-19(1) Salconrasvilas, D-1, District New Delhi Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Dcit Vs Oracle India Private Limited Circle-19(1) F-01/02, 1St Floor, Salcon New Delhi Rasvilas, D-1, District Centre, Saket, New Delhi Pan: Aaaco0158L Appellant Respondent Assessee By Sh. Naveen Dhamija, Ca, Sh. Vishal Aggarwal, Ca& Sh. Rinku Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 28/01/2026

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as Oracal India Vs. Addl. CIT and when such order

BAXTER (INDIA) PRIVATE LTD.,GURGAON vs. DCIT CIRCLE-4(2), , DELHI

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

BAXTER INDIA PVT. LTD.,GURGAON vs. ACIT, CIRCLE- 4(1), NEW DELHI

In the result, appeals of the Assessee are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalbaxter India Pvt. Ltd. Vs Acit 2Nd Floor, Tower C, Building Circle 4 (1) No. 8, Dlf Cyber City, Dlf C. R. Building, Phase-Ii, Gurgaon New Delhi Pan: Aaacb3906F Appellant Respondent

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

FENA PVT. LTD.,NEW DELHI vs. ADDL. CIT NATIONAL FACELESS CENTRE, NEW DELHI

Bench: Shri Yogesh Kumar U.S. & Shri Krinwant Sahay, Accountnat Member

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 22[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner

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

260A. (4) Where the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the order of the Appellate Tribunal, as the case may be, referred to in sub-section (1) is not in conformity with the final decision on the question of law in the other case, as and when such order is received, the Principal Commissioner