$~1 to 5 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 730/2025 + ITA 733/2025 + ITA 734/2025 GUJARAT GUARDIAN LTD .....Appellant Through: Mr. Ajay Vohra, Sr. Adv. with Mr.

Neeraj Jain, Mr. Aniket D. Agrawal, Mr. Kunal Panday and Mr. Samarth Chaudhari, Advs.

versus DEPUTY COMMISSIONER OF INCOME TAX .....Respondent Through: Mr. Shlok Chandra, SSC Ms. Naincy Jain, Ms. Madhvi Shukla, JSCs with Mr. Udit Dad, Adv.

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE SAURABH BANERJEE

O R D E R

% 10.12.2025

1. Admit.

2. The following substantial questions of law are framed in these appeals.

For Assessment Year 2002-03 [ITA No. 669/2025]

1. Whether in the facts and circumstances of the case, the Tribunal erred in law in holding that the appellant- assessee was not entitled in law to raise the claim relating to treatment of the amount received as sales tax subsidy/incentive in the course of proceedings under section 147/148 of the Act?

2. Whether in the facts and circumstances of the case, the Tribunal erred in holding that the sales tax subsidy/incentive received/availed by the appellant- assessee under the ‘Special Incentives for Pioneer Units, 1986 Scheme’ read with the ‘Composite Sal