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Commissioner Of Income Tax (International Taxation)- 2, Delhi v. M/S Michelin Global Mobility S.a

High Court 26 Sep 2024 In favour of: Assessee
Forum / Bench
High Court · dhcdb
Parties
Commissioner Of Income Tax (International Taxation)- 2, Delhi v. M/S Michelin Global Mobility S.a
Date of order
26 Sep 2024
Assessment year(s)
2015-16
Outcome
Dismissed

The order — as passed by the High Court

Case summary

In Commissioner Of Income Tax (International Taxation)- 2, Delhi v. M/S Michelin Global Mobility S.a, the High Court (2024) dismissed the appeal. The decision went in favour of the assessee.

Decision: The learned counsels also do not dispute that the subject matter does not fall in any of the exceptions, as provided in the said circular.5.Accordingly, the present appeal is dismissed, on account of low tax effect.

Summary auto-generated from the order below — read the full judgment for the complete reasoning.
$~2 * IN THE HIGH COURT OF DELHI AT NEW DELHI+ ITA 284/2024 COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)- 2, DELHI .....Appellant Through: Mr. Vipul Agrawal, Senior Standing Counsel with Mr. Gibran Naushad, Junior Standing Counsel & Ms. Sakashi Shairwal, Junion Standing Counsel. versus M/S MICHELIN GLOBAL MOBILITY S.A. .....Respondent Through: Ms. Ananya Kapoor for Mr. Salil Kapoor & Mr. Sumit Lal, Advocates. CORAM:HON'BLE MR. JUSTICE VIBHU BAKHRUHON'BLE MS. JUSTICE SWARANA KANTA SHARMA O R D E R26.09.2024 % -CM APPL. 28960/2024 (condonation of delay in refiling the present income tax appeal) 1. For the reasons as stated in the application, the same is allowed. The delay in re-filing the income tax appeal is condoned. 2. The application is disposed of accordingly. ITA 284/2024 3. The Revenue has filed the present appeal, impugning the order dated 15.12.2022, passed by the learned Income Tax Appellate Tribunal, in ITA No. 1962/DEL/2020, for the Assessment Year 2015-16. The impugned order is a common order passed in two appeals preferred by the Revenue, for the Assessment Years 2015-16 and 2016-17. 4.It has been pointed out that the tax effect in the present appeal is below the threshold limit of ₹2 crores, as stipulated in the circular dated 17.09.2024. The learned counsels also do not dispute that the subject matter does not fall in any of the exceptions, as provided in the said circular.5.Accordingly, the present appeal is dismissed, on account of low tax effect. VIBHU BAKHRU, J SEPTEMBER 26, 2024 at SWARANA KANTA SHARMA, J Click here to check corrigendum, if any
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