ITA Nos.7/2023

Page 1 of 11

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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Judgment Pronounced on: 13.12.2023

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ITA 7/2023 & CM APPL. 920/2023

PR. COMMISSIONER OF INCOME TAX – 8

..... Appellant

Through:

Mr Zoheb Hossain, Senior Standing

Counsel along with Mr Sanjeev

Menon, Standing Counsel.

versus

M/S SONY INDIA PVT. LTD.

..... Respondent

Through:

Mr Nageswar Rao, Mr Parth, and Ms

Maher Verma, Advs.

CORAM:

HON'BLE MR. JUSTICE RAJIV SHAKDHER

HON'BLE MR. JUSTICE GIRISH KATHPALIA

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

RAJIV SHAKDHER, J.:

Prefatory facts:

1. This appeal concerns Assessment Year (AY) 2007-08. Via the instant

appeal, the appellant/revenue seeks to assail the order dated 21.12.2018

passed by the Income Tax Appellate Tribunal [hereafter referred to as “the

Tribunal”].

2. Although a perusal of the appeal discloses that three (3) questions are

proposed on behalf of the appellant/revenue, in substance, they veer around

one (1) issue, which is, whether the reimbursement of advertising, marketing

and promotion expens