IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA Nos. 4219 and 4240/MUM/2025 Assessment Years: 2017-18 and 2018-19 Assistant Commissioner of BCD Travel Services BV Income-tax (IT) - 1.2.2, 400 Europalaan, Mumbai Utrecht – 3526KS, Vs. The Netherlands, Nederland, Not Listed, 999999 [PAN: AAECB9053H]

(Appellant) (Respondent)

Present for:

Assessee : Ms. Hirali Desai, Shri Hardik Nirmal and Ms. Tejal Saraf, CAs Revenue : Shri Krishna Kumar, Sr. DR Date of Hearing : 19.08.2025 Date of Pronouncement : 29.09.2025

O R D E R

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These two appeals filed by Revenue are against the orders of CIT (A) 55, Mumbai, vide order Nos. ITBA/APL/S/250/2024- 25/1075169546(1) and ITBA/APL/S/250/2024-25/1075170902(1), dated 28.03.2025 passed against the assessment orders by International Taxation, Tax Circle-1(2)(2), Mumbai, u/s. 143(3) r.w.s 144C(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 21.01.2020 for Assessment Year 2017-18 and dated

01.06.2021 for Assessment Year 2018-19, respectively.

2. Grounds taken by the Revenue are reproduced as under:

I