2025 (2) TMI 456

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....MR. JUSTICE TUSHAR RAO GEDELA For the Appellant Through: Mr. Ruchir Bhatia, SSC. For the Respondent Through: Mr. Vishal Kalra, Advocate. JUDGEMENT TUSHAR RAO GEDELA, J.: (ORAL) CM APPL. 7533/2025 & CM APPL. 7534/2025 1. Cause shown is sufficient. Accordingly, the application is allowed. Delay of 164 days in filing as well as delay of 40 days in refilling the appeal is condoned. ....

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....6 (SC) and not the exception, stipulated in the said judgment and hence nothing further is attributable to the assessee's PE in India despite that fact that Adobe India is performing functions which are wider in scope than what is mentioned in the agreement between the two entities and the TP Study Report of Adobe India? 2.2 Whether on the facts and circumstances of the case, and in l....

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....th 2.4 Whether on the facts and circumstances of the case, and in law, the Ld. ITAT has erred in not passing a speaking order on whether Adobe India constitutes a PE of Adobe Ireland?" 5. Mr. Bhatia, learned senior standing counsel for the revenue fairly states that all the substantial questions of law raised in this appeal is no more res integra and has been decided against the appell....