Condonation granted for appeal delay; questions of law addressed; interest not warranted.

The appellant sought condonation of a 300-day delay in re-filing appeals, which was not opposed by the respondent. The court disposed of the condonation applications and found that the questions of law raised by the appellant were already addressed in previous decisions, not requiring further consideration. The court concluded that interest under Section 234B was not warranted, leading to the closure of the appeals based on existing legal precedents and Tribunal's observations.

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Issues involved: Application for condonation of delay in re-filing appeals, questions of law concerning profit determination, tax treatment of booking fee, and interest under Section 234B of the Income Tax Act.

Condonation of Delay:
- The appellant sought condonation of a 300-day delay in re-filing the appeals.
- The respondent did not oppose the request, leading to the delay being condoned.
- The applications for condonation were disposed of.

Questions of Law:
- The appeals pertained to Assessment Years 2013-14 to 2016-17 and challenged a common order by the Income Tax Appellate Tribunal.
- The appellant raised questions regarding profit determination, tax treatment of booking fee, and interest under Section 234B of the Income Tax Act.
- The appellant argued that the Tribunal erred in adopting a 15% profit figure for the appellant's Permanent Establishment in India, taxing booking fees as business income instead of royalty, and not levying interest under Section 234B.
- The appellant's counsel acknowledged that the questions raised were already addressed in previous court decisions.
- The court found that none of the proposed questions of law required consideration as they were covered by existing legal precedents.
- The Tribunal's observations supported the conclusion that interest under Section 234B was not warranted in this case.
- Consequently, the appeals were closed, and parties were directed to act based on the digitally signed copy of the order.

This summary provides a detailed overview of the issues involved in the legal judgment, including the application for condonation of delay and the questions of law raised by the appellant regarding profit determination, tax treatment, and interest under the Income Tax Act. The court's decision to close the appeals based on existing legal precedents and the Tribunal's observations is highlighted, emphasizing the resolution of the case.

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