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2023 Supreme(Del) 4103

RAJIV SHAKDHER, GIRISH KATHPALIA
Commissioner of Income Tax (international Taxation)-2 – Appellant
Versus
Intelsat Us Llc – Respondent


Advocates appeared:
Mr Sanjay Kumar, Senior Standing Counsel with Ms Hemlata Rawat and Ms Easha, Advocates, for the Appellant.
Mr S.S. Tomar with Mr Ankit Sahani, Advocates, for the Respondent.

JUDGMENT

[Physical Hearing/Hybrid Hearing (as per request)]

Rajiv Shakdher, J. (Oral)

1. This appeal concerns Assessment Year (AY) 2019-20.

2. Via this appeal, the appellant/revenue seeks to assail the order dated 31.01.2023 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"].

3. Mr Sanjay Kumar, learned senior standing counsel, who appears on behalf of appellant/revenue, fairly informs us that the issue raised in the present appeal is covered by the decision of this Court dated 24.07.2023 rendered in ITA No. 395/2023, titled Commissioner of Income Tax (International Taxation)-2 vs. Intelsat US LLC (Erstwhile Intelsat Corporation).

4. The said decision concerns AY 2018-19. While disposing the appeal, we had made the following observations:

    "7. Broadly, the appeal concerns the additions made by the assessing officer vis-a-vis payment received for rendering satellite transponder facilities by the respondent/assessee to its customers in India.

    8. We are told by Mr Sanjay Kumar, learned senior standing counsel, who appears on behalf of the appellant/revenue, that the issue raised in the present appeal is covered by the decisions rendered by the coordinate benches in M/s

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