2025 (1) TMI 978

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....doria, Adv ORDER Leave granted. 2. The appellant herein had preferred ITA NO.267 of 2023 before the High Court of Delhi, raising certain substantial questions of law. 3. Learned senior counsel for the appellant submitted that on 18.05.2023, learned counsel on behalf of the appellant expressly submitted before the High Court that two substantial questions of law raised in the appeal was covered by the judgment of this Court in Checkmates Services Pvt. Ltd. vs. Commissioner of Income Tax (2022 SCC OnLine SC 1423) and therefore, only one substantial question of law remains for consideration. On the basis of the said submission, the High Court considered only one substantial question of law and answered the said substantial question of law....

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....the appellant is aggrieved. The same is taken on record. 4. Per contra, learned Additional Solicitor General appearing for the respondent submitted that the impugned order dated 05.09.2023 in this appeal, per se, would not call for any interference at all. It was on the basis of the submission made by learned counsel for the appellant herein that the High Court proceeded to consider only one of the substantial questions of law and observed that the other two substantial questions of law were covered by the Judgment of this Court in Checkmates Services Pvt. Ltd. (supra). Thus where the appellant cannot now seek to assail the order dated 05.09.2023 in this appeal in the absence of there being any challenge to the order dated 18.05.2023 inasm....