2025 (8) TMI 424

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....tion 147/144C(13) r.w.s.143(3) of the Income Tax Act, 1961 (hereinafter, the 'Act') by the Deputy Commissioner of Income Tax, Circle-1(3)(1),(International Taxation), New Delhi [hereinafter, the 'Assessing Officer'/'AO']. 2. Vide 20 grounds, the issues raised in this appeal are as under: - (i) Re-opening of the assessment (Ground Nos. 2 and 3) (ii) Taxability of income from Offshore supplies (Ground Nos. 4 to 11) (iii) Profit attributable to PE in India (Ground Nos. 12 to 19) (iv) Levying of interest under section 234B of the Act (Ground Nos. 20). 3. The brief facts giving rise to this appeal are that the assessee, a non-resident, incorporated in Italy, is a supplier of compressors, pumps and its ac....

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....e Dispute Resolution Pannel (hereafter, the 'DRP'). However, it did not succeed there. Consequentially, the final assessment was completed, vide impugned order, at income of Rs. 82,95,49,379/-. 4. Before us, the Ld. Authorized Representative (hereinafter, the 'AR'), at the outset, submitted that the Ground No. 1 being general in nature, was not pressed. Further, he submitted that the issue of reopening raised vide Ground Nos. 2 and 3 and the issue of income derived from offshore supplies raised vide Ground Nos. 4 to 11 had been decided against the appellant/assessee in its own case for the AY 2009-10 by the Hon'ble Delhi High Court in the ITA No. 491/2019 & CM Appl. 23000/2019 and W.P(C) 6494/2019 dated 19.09.2024. Hence, these issues sh....