ARGOS HOLDINGS PTE. LTD. SINGAPORE vs DEPUTY COMMISSIONER OF INCOME TAX CIRCLE INT TAX 1(1)(1) DELHI DELHI

Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(Online)(ITAT) 6861

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
ARGOS HOLDINGS PTE. LTD. SINGAPORE – Appellant
Versus
DEPUTY COMMISSIONER OF INCOME TAX CIRCLE INT TAX 1(1)(1) DELHI DELHI – Respondent

Table of Content
1. introduction to appeals and assessment order. (Para 1 , 2)
2. legal grounds for additional appeal. (Para 3 , 5 , 6)
3. evidence of foreign company status. (Para 10 , 18)
4. jurisdictional issues and statutory obligations. (Para 20 , 21)
5. conclusion and resolution of appeal. (Para 22 , 23)

ORDER

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1. These appeals preferred by the assessee are directed against the assessment order dated 31.03.2025 passed by the DCIT, Circle Int. Tax 1(1)(1), Delhi under section 147 read with section 260 of the Income-tax Act, 1961 (for short ‘the Act”) for Assessment Years 2015-16 & 2017- 18pursuant to the directions of the Dispute Resolution Panel u/s 144C(5) of the Act.

2. Since the issues are common and the appeals are connected, hence the same are heard together and being disposed off by this common order. First, we take up AY 2015-16 as the lead case.

3. At the outset of the hearing, ld. AR submitted that assessee has filed additional grounds of appeal under Rule 11 of the Income Tax (Appellate Tribunal) Rules and it is purely legal issue and the same is reproduced below :-

“1. That the Appellant being a foreign company having no Permanent Esta