IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.5246/MUM/2025 ITA No.5252/MUM/2025 (Assessment Year: 2018-19) (Assessment Year: 2018-19)

ITA No.5247/MUM/2025 ITA No.5253/MUM/2025 (Assessment Year: 2018-19) (Assessment Year: 2018-19)

ITA No.5248/MUM/2025 ITA No.5254/MUM/2025 (Assessment Year: 2018-19) (Assessment Year: 2019-20)

ITA No.5249/MUM/2025 ITA No.5255/MUM/2025 (Assessment Year: 2018-19) (Assessment Year: 2019-20)

ITA No.5250/MUM/2025 ITA No.5256/MUM/2025 (Assessment Year: 2018-19) (Assessment Year: 2019-20)

ITA No.5251/MUM/2025 ITA No.5257/MUM/2025 (Assessment Year: 2018-19) (Assessment Year: 2019-20)

Income Tax Officer (International Taxation), Ward-1(2)(2), Room No.621, D, Kautilya Bhawan, ............... Appellant G-Block, BKC, Mumbai v/s Bennett Coleman & Co. Ltd., Times of India Building, D.N. Road, ……………… Respondent Mumbai – 400001 PAN : AAACB4373Q Assessee by : Shri Ajit Jain Ms. Riddhi Soni Shri Jeet Gada Revenue by : Shri Krishna Kumar, Sr.DR Date of Hearing – 07/01/2026 Date of Order - 14/01/2026

O R D E R

PER BENCH:

The Revenue has filed the present appeals against th