The Pr. Commissioner Of Income Tax -7 v. Samsung India Electronics Pvt. Ltd.

$~47 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 425/2024 THE PR. COMMISSIONER OF INCOME TAX -7....Appellant Through:

Mr. Ruchir Bhatia, SSC and Mr. Anant Mann, Mr. Pratyush Gupta, JSCs.

versus SAMSUNG INDIA ELECTRONICS PVT. LTD.....Respondent Through:

Mr. Himanshu S. Sinha, Mr.

Prashant Meharchandani, Mr.

Jainender Singh Kataria, Advocates.

CORAM:

HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE RAVINDER DUDEJA

O R D E R

% 08.08.2024 CAV 371/2024 Since learned counsel for the caveator/respondent has entered appearance, the caveat stands discharged.

CM APPL. 45322/2024 (760 days delay) Bearing in mind the disclosures made, the delay of 760 days in refilling the appeal is condoned.

The application shall stand disposed of.

ITA 425/2024 1.

The Principal Commissioner impugns the order of the Income Tax Appellate Tribunal ['Tribunal'] dated 31 August 2020. 2.

We note that both the issues in question i.e. Advertisement, Marketing and Promotion ['AMP'] as well as the exclusion of M/s 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 13/08/2024 at 11:43:05

OTS E-Solutions Pvt. Ltd as a comparable stands answered against the appellant in light of the judgment dated 05 August 2024 rendered by us on ITA 419/2024.

3.

Consequently and following the aforesaid decision, this appeal shall stand dismissed.

YASHWANT VARMA, J.

RAVINDER DUDEJA, J.

AUGUST 8, 2024/vp 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 13/08/2024 at 11:43:05