2026 (2) TMI 769

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.....03.2025 (wrongly dated) so also the consequential certificate dated 21.08.2025 passed/issued by respondent No. 1 (hereinafter referred to as 'Competent Authority') under Section 197 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act of 1961'). 2. As per the petitioner, it is engaged in the business of providing domain name services, including domain name registration, web hosting, web designing, SSL certification, etc. 3. Mr. Sachit Jolly, learned Senior Counsel submitted that the petitioner had not only succeeded in its appeal before the Income Tax Appellate Tribunal Delhi Benches 'D', New Delhi (hereinafter referred to as 'Tribunal'), but said order has been affirmed by this Court in the case of GoDaddy.com LLC vs. As....

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....ddhartha Sinha, learned Senior Standing counsel for the Department could not defend the impugned order passed by the Competent Authority by any manner, though he tried his best. 7. Heard learned counsel for the parties and perused the record. 8. On perusal of the order dated 06.03.2025, we find that no reason other than the bald assertion that the Department is proposing to file an SLP against the order dated 11.12.2023 has been assigned by the Competent Authority in the impugned order. Such reason, according to us cannot be said to be a reason in the eyes of law, much less a plausible or sustainable one. While noticing that limitation of filing SLP has since passed, we are constrained to record that impugned order unravels the mindse....