IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, D: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER [Assessment Year: 2018-19]

Shivi Srivastava, DCIT or ADIT (Int. Tax), A-602, ATS Greens, Sector-50, Noida, Uttar Pradesh-201301. Vs Uttar Pradesh.

PAN- AAVPY7375F Assessee Revenue Assessee by Ms. Reema Grewal, CA Revenue by Shri M.S. Nethrapal, CIT(DR)

Date of Hearing 18.12.2025 Date of Pronouncement 18.12.2025

ORDER

PER BRAJESH KUMAR SINGH, AM, This appeal has been preferred by the assessee against the order dated

26.03.2024 of the Commissioner of Income Tax (International Taxation)-3, Delhi, [hereinafter referred to as the ‘Ld. CIT] Delhi, pertaining to Assessment Year 2018- 19, vide which the Assessment order dated 12.04.2021 passed under Section 143(3) of the Income-tax Act, 1961(hereinafter referred to as ‘the Act’) by the DDIT/ADIT (In. Tax.), Noida (hereinafter referred to as ‘the AO’) was set aside on the issues raised in the show cause notice dated 08.03.2024. In the show cause notice, the issue related to the taxability of salary of Rs. 86,16,798/- from M/s Continental India Private Limited in India and salary of RMB 10,52,7