The Commissioner Of Income Tax - International Taxation -3 v. Six Continents Hotels Inc.

$~61 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 211/2026 THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 .....Appellant Through:

Mr. Ruchir Bhatia, SSC with Mr.

Anant Mann & Mr. P. Gupta, JSCs versus SIX CONTINENTS HOTELS INC.

.....Respondent Through:

Mr. Manu Sabharwal, Mr. Devvrat Tiwari & Mr. Drona Negi, Advs.

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R

% 19.03.2026 1.

Learned counsel for the respondent at the outset submitted that in the case of very same assessee, the appeal filed by the Department on the very same grounds has been rejected by Coordinate Bench of this Court on 17.04.2025 (Appeal No. 554/2024) and therefore, instant appeal also deserves to be dismissed.

2.

Mr. Ruchir Bhatia, learned counsel for the appellant could not dispute the aforesaid fact situation.

3.

In view of the above and having gone through the order dated 17.04.2025 passed in ITA 554/2024, we find that the issue involved in the present appeal is exactly identical to the facts relating to ITA 554/2024. 4.

Instant appeal, therefore, fails.

DINESH MEHTA, J.

VINOD KUMAR, J.

MARCH 19, 2026/sr The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 23/03/2026 at 10:52:14