The Commissioner Of Income Tax - International Taxation -2 v. Inmarsat Solutions Bv
High Court
31 May 2024 In favour of: Revenue
Forum / Bench
High Court · dhcdb
Parties
The Commissioner Of Income Tax - International Taxation -2 v. Inmarsat Solutions Bv
Date of order
31 May 2024
Assessment year(s)
—
Outcome
Allowed
Case summary
In The Commissioner Of Income Tax - International Taxation -2 v. Inmarsat Solutions Bv, the High Court (2024) allowed the appeal. The decision went in favour of the Revenue.
Decision: Consequently, and in view of the aforesaid, the appeals shall stand dismissed.
Summary auto-generated from the order below — read the full judgment for the complete reasoning.
The order — as passed by the High Court
$~15, 16 & 26
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ ITA 310/2024
THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -2
..... Appellant Through: Mr. Ruchir Bhatia, SSC along with Mr. Anant Mann, Mr. Pratyaksh Gupta, JSCs and Mr. Vikram Chand, Adv.
versus
INMARSAT SOLUTIONS BV
..... Respondent Through: None.
16
+ ITA 311/2024 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -2
..... Appellant
Through:
Mr. Ruchir Bhatia, SSC along with Mr. Anant Mann, Mr. Pratyaksh Gupta, JSCs and Mr. Vikram Chand, Adv.
versus
INMARSAT SOLUTIONS BV
..... Respondent
Through: None.
26
+ ITA 313/2024
THE COMMISSIONER OF INCOME TAX -
INTERNATIONAL TAXATION -2 ..... Appellant
Through: Mr. Ruchir Bhatia, SSC along with Mr. Anant Mann, Mr. Pratyaksh Gupta, JSCs and Mr. Vikram Chand, Adv.
versus
INMARSAT SOLUTIONS BV
..... Respondent
Through: None.
CORAM:HON'BLE MR. JUSTICE YASHWANT VARMAHON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV
%
O R D E R
31.05.2024
CM APPL. 34510/2024 (Exemption) in ITA 311/2024
Allowed, subject to all just exceptions.
Application is disposed of.
CM APPL. 34491/2024 (35 Days Delay in Refiling) in ITA310/2024
CM APPL. 34511/2024 (35 Days Delay in Refiling) in ITA311/2024
CM APPL. 34769/2024 (35 Days Delay in Refiling) in ITA313/2024
Bearing in the mind the disclosures made, the delay of 35 days’ in re-filing the appeals is condoned.
Applications shall stand disposed of.
[ITA 310/2024, ITA 311/2024 & ITA 313/2024]
Having heard learned counsel for the appellant and on going through the judgment rendered by the Income Tax Appellate Tribunal [‘Tribunal’], we find that the issues raised here stand concluded against the appellant in light of the decision rendered in Asia Satellite Telecommunications Co. Ltd. vs. DIT [2011 SCC OnLine Del 507] as well as DIT vs. New Skies Satellite BV [2016 SCC OnLine Del 796].
Consequently, and in view of the aforesaid, the appeals shall stand dismissed.
YASHWANT VARMA, J.
MAY 31, 2024/RW
PURUSHAINDRA KUMAR KAURAV, J.
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