Facts of the Case

The matter pertains to multiple cross appeals filed by both the assessee (McKinsey Knowledge Centre India Pvt. Ltd.) and the Revenue (Pr. Commissioner of Income Tax, Delhi-6) before the Delhi High Court.

These appeals arose from questions of law framed in earlier proceedings, particularly in ITA 461/2017 and connected matters. The disputes involved determinations made under the Income Tax Act, 1961.

The present order is a common disposal of multiple connected appeals, where both parties challenged findings on similar legal issues.

Issues Involved

  1. Whether the questions of law framed in ITA 461/2017 and ITA 526/2017 were to be decided in favour of the Revenue or the Assessee.
  2. Whether the Revenue’s appeals in ITA 590/2017 and ITA 82/2018 were sustainable in law.
  3. Whether the findings in the connected judgment dated 09.08.2018 (ITA 461/2017) governed the present appeals.

Petitioner’s (Assessee’s) Arguments

  • The assessee challenged the findings of the lower authorities by raising substantial questions of law.
  • It sought relief by contending that the legal issues should be decided in its favour in ITA 526/2017 and connected matters.

Respondent’s (Revenue’s) Arguments

  • The Revenue argued in support of its appeals (ITA 590/2017 & ITA 82/2018).
  • It also defended the findings against the assessee in the connected appeals.

Court Findings / Judgment

  • The High Court held that:
    • The questions of law in ITA 461/2017 and ITA 526/2017 were answered against the assessee, leading to dismissal of the assessee’s appeals.
    • The questions of law in ITA 590/2017 and ITA 82/2018 were answered against the Revenue and in favour of the assessee, resulting in dismissal of the Revenue’s appeals.
  • Consequently, all appeals were dismissed without any order as to costs.

Important Clarification by Court

  • The Court clarified that for detailed reasoning, reference must be made to the judgment dated 09.08.2018 in ITA 461/2017, which governs the issues involved in these appeals.

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

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