Commissioner of Income Tax, International TAXATION-3, Delhi v. Turner Broadcasting System Asia Pacific Inc.
Case brief
What is this about?
Delhi High Court, ITA 7/2026 and ITA 9/2026, decided 09.01.2026; Coram: Dinesh Mehta, J and Vinod Kumar, J. Appellant: Commissioner of Income Tax, International Taxation-3, Delhi (counsel: Puneet Rai SSC, Gibran JSC, Ashvini Kumar, Rishabh Nangia). Respondent: Turner Broadcasting System Asia Pacific Inc (counsel: Rohan Khan, Priyam Bhatnagar). Appeals for AY 2022-23 and AY 2018-19 dismissed following coordinate bench rulings in ITA No.76/2025 (judgment dated 26.03.2025) and ITA No. 232/2025 (judgment dated 04.08.2025). Key themes: identical issues, MAP (Mutual Agreement Procedure) resolution, same agreement(s), business income accepted by Revenue, no substantial question of law, wider question of law left open.
What did the court decide?
Following the Coordinate Bench judgment dated 26.03.2025 in ITA No.76/2025 and the judgment dated 04.08.2025 in ITA No. 232/2025, both these appeals are dismissed.