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2026 Supreme(Online)(ITAT) 364

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
FCS COMPUTER SYSTEMS S PTE LTD INDIA – Appellant
Versus
ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE INT TAX 1(3)(1) INDIA – Respondent


INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER (Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

(Assessment Year: 2022-23)

O R D E R

PER M. BALAGANESH, A. M.:

1. The appeal in ITA No. 1034/Del/2025 for AY 2012-13, arise out of the order of the Commissioner of Income Tax (Appeals)-42, New Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] in Appeal No. 24/15- 16/CIT(A)-42 A.Y. 2012-13 dated 24.10.2016 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 26.05.2015 by the Assessing Officer, ACIT, Circle-1(3)(1), International Taxation, New Delhi (hereinafter referred to as ‘ld. AO’).

2. The assessee has raised the following grounds of appeal before us:-

“1. That having regard to the facts and circumstances of the case, the impugned order

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