Commissioner of Income Tax, International TAXATION-3, Delhi v. Turner Broadcasting System Asia Pacific Inc.
Case brief
What is this about?
Income Tax Appeals ITA 7/2026 (AY 2022-23) and ITA 9/2026 (AY 2018-19) by Commissioner of Income Tax, International Taxation-3, Delhi against Turner Broadcasting System Asia Pacific Inc., dismissed by Delhi High Court (Dinesh Mehta & Vinod Kumar, JJ.) on 09.01.2026 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. Identical issues: taxability of receipts similar to revenue resolved under Mutual Agreement Procedure (MAP), same agreement(s), Revenue having earlier accepted the income as business income; no substantial questions 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 of this Court, both appeals (ITA 7/2026 and ITA 9/2026) are dismissed.