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2022 (10) TMI 183
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.... taken up together for hearing and are being disposed off by way of consolidated order for the sake of brevity. 2. First we take up the Revenue's appeal in ITA No. 807/Del/2019 pertaining to Assessment Year 2013-14. The Revenue has raised following grounds of appeal:- ITA No.807/Del/2019 [Assessment Year : 2013-14] 1. "Whether the Ld. CIT (A) has erred on facts and in law by deleting the addition of profit of Rs. 35,24,68,933/- of the assessee from providing technical services to other airlines. 2. Whether profit of the assessee from providing technical services to other airlines is covered by Articles 8(1) and 8(4) of the DTAA between India and Germany, and by Articles 8(1) and 8(3) of the DTAA between I....
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....eing told that the case is covered by Hon'ble Delhi High Court decision in assessee's own case chose to ignore the Hon'ble High Court decision and decide the issue against the assessee. Ld. DR for the Revenue, on the other hand, could not dispute the submission that identical issue has been decided in favour of the assessee by Hon'ble Delhi High Court. 9. Upon careful consideration, we note that Hon'ble Delhi High Court in the case of the assessee for assessment years 2004-05 to 2008-09 by the order dated 25.01.2017 (392 ITR 218) elaborately dealt with the issue. The question considered by the Hon'ble High Court was :- "Whether profits of the assessee from providing technical services to other airlines is covered by Ar....