IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, F: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA Nos.- 3083 & 3084/Del/2017 [Assessment Years: 2008-09 & 2009-10]

Additional commissioner of M/s PHI Seeds Pvt. Ltd., Income Tax, (Now known as Corteva Special Range-7, Vs Agriscience Seeds Pvt. Ltd.)

Room No. -211, CR Building, 3rd Floor, 6-3-1099/1100, IP Estates, Babukhans Millenium New Delhi-110002, Centre, Raj Bhawan Road, Somajiguda, Hyderabad-500082. PAN- AACCP3920F Revenue Assessee Revenue by Ms. Monika Singh, CIT(DR)

Assessee by Shri Sandeep Bansal, CA, Ms Deepika Gupta, CA Date of Hearing 16.10.2025 Date of Pronouncement 31.10.2025 ORDER PER BRAJESH KUMAR SINGH, AM:

These two appeals filed by the Revenue are against the respective orders of the Ld. Commissioner of Income Tax (Appeals)- 7, New Delhi, dated 23.02.2017 and 27.02.2017 arising from penalty orders both dated 27.03.2015 passed under section

271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to Assessment Years 2008-09 and 2009-10. The respective penalty proceedings for both the Assessment Years i.e. for A.Ys. 2008-09 and 2009-10