Facts of the Case

The present matter concerns a batch of cross-appeals filed by both the assessee, McKinsey Knowledge Centre India Pvt. Ltd., and the Revenue, represented by the Principal Commissioner of Income Tax, Delhi-6, before the Delhi High Court.

The appeals arose from Income Tax Appellate proceedings involving questions of law relating to transfer pricing and income tax assessment issues. The matters were interconnected with earlier appeals, particularly ITA No. 461/2017, wherein similar legal questions had already been adjudicated.

The Court, as reflected on Page 2 of the judgment, noted that the issues raised in the present appeals were identical to those decided in the earlier judgment dated 09.08.2018.

Issues Involved

  1. Whether the questions of law raised in the present appeals required independent adjudication.
  2. Whether the findings in the earlier connected judgment (ITA 461/2017) were applicable to the present appeals.
  3. Whether the appeals filed by the assessee and the Revenue were sustainable in law.

Petitioner’s Arguments (Assessee – McKinsey Knowledge Centre India Pvt. Ltd.)

  • The assessee challenged the findings of the lower authorities regarding income tax and transfer pricing adjustments.
  • It was contended that the questions of law framed required reconsideration and were not correctly adjudicated previously.
  • The assessee sought relief by distinguishing its case from earlier rulings.

Respondent’s Arguments (Revenue – PCIT Delhi-6)

  • The Revenue argued that the issues raised were already conclusively decided in the earlier judgment (ITA 461/2017).
  • It was submitted that no new substantial question of law arose in the present appeals.
  • The Revenue maintained that the appeals deserved dismissal in light of the binding precedent.

Court’s Findings / Order

  • The Delhi High Court held that the questions of law framed in the assessee’s appeals (ITA 461/2017 & ITA 526/2017) were answered against the assessee.
  • Similarly, the questions of law in the Revenue’s appeals (ITA 590/2017 & ITA 82/2018) were answered against the Revenue and in favour of the assessee.
  • Consequently, all appeals were dismissed without any order as to costs.
  • The Court clarified that for detailed reasoning, reference should be made to the judgment dated 09.08.2018 in ITA 461/2017.

Important Clarification

  • The judgment is not a detailed reasoning order, but a follow-up disposal order relying on a previously decided case.
  • It emphasizes the principle that once a question of law is settled in a connected matter, identical appeals can be disposed of accordingly without re-litigation.
  • The decision reinforces judicial consistency and avoidance of repetitive adjudication                

Sections Involved

  • Income Tax Act, 1961
    • Section 260A (Appeal to High Court)
    • Transfer Pricing Provisions (General applicability, though not explicitly detailed in this short order

Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2018:DHC:4976-DB/SRB09082018ITA5262017.pd

Disclaimer

This content is shared strictly for general information and knowledge purposes only. Readers should independently verify the information from reliable sources. It is not intended to provide legal, professional, or advisory guidance. The author and the organisation disclaim all liability arising from the use of this content. The material has been prepared with the assistance of AI tools.