IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: D: NEW DELHI BEFORE SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER AND SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER ITA No.3314/Del/2013 [AY : 2006-07] ITA No.5671/Del/2011 [AY : 2007-08] ITA No.4054/Del/2014 [AY : 2008-09] ITA No.1974/Del/2014 [AY : 2009-10]

ITAs No.2088, 2089 & 2090/Del/2017 [AYs : 2010-11 to 2012-13]

Oracle Systems Corporation, v. Addl. Director of Income-tax, C/o Oracle India Private limited, Range-2, F-01/02, 1^st Floor, Salcon International Taxation, Rasvilas, New Delhi.

D-1, District Centre, Saket, New Delhi – 110 017. PAN: AAACO0207A (Appellant) (Respondent)

Assessee by : Shri G.C. Srivastava, Advocate Shri Kalrav Mehrotra, Advocate, Shri O.P. Mehra, Consultant, Shri Atishay Jain, CA, Shri Shubham Bansal, Advocate &

Shri Pushpak Garg, CA Revenue by : Shri Indruj Singh Rai, Special Counsel Date of Hearing : 19.01.2026 Date of Pronouncement : 02.03.2026 ORDER PER Bench:

These seven appeals for the respective assessment year’s detailed hereunder have been filed by the assessee against the separate assessment orders read with ld. Dispute Resolution Panel orders , or ld. Commissioner of Income-

tax(Appeals) appellate orders, as detailed below:-

2. At the outset, the Ld. counsel for the assessee, Shri G.C. Srivastava, Advocate brought to the notice of the Bench that the assessee has raised an additional ground of appeal in the respective years with respect to limitation i.e. that the assessment order passed by ld. AO u/s 143(3) is barred by limitation keeping in view the provisions of Section 144C of the Act with respect to assessment years in which draft assessment order passed by the AO is challenged before ld. DRP. It was prayed that the assessee does not wish to press the said additional ground of appeal raised with respect to challenge on grounds of limitation, and prayers were made to dismiss the aforesaid ground of limitation as raised by the assessee with the Tribunal. The ld. CIT-DR has no objection if the aforesaid additional ground of appeal raised by the assessee with respect to limitation is dismissed as being withdrawn. After hearing both the parties, we dismiss the additional ground of appeal raised by the assessee with respect to the assessment order(s) being barred by limitation as being withdrawn , in the aforesaid relevant assessment years wherein draft assessment order is challenged by the assessee before ld. DRP. We order accordingly.

3. Further, when these bunch of seven appeals were taken up for hearing, both the parties, at the outset, brought to the notice of the Tribunal that the majority of the issues which have arisen in these seven appeals have already been adjudicated by the Tribunal in asssessee’s own case vide recent common order dated 2^nd January, 2026 in ITA Nos.1833 to 1836/Del/2009 and ITA No.3313/Del/2013 for AYs 2001-02 to 2005-06. Both the parties are ad-idem that the factual matrix are same in the instant assessment years presently before this Bench for adjudication vis-a-vis for ay(s) : 2001-02 to 2005-06 except variation in the amounts, and both the parties are ad-idem that the aforesaid decision rendered by the Tribunal in assessee’s own case vide common order dated 02.01.2026 for the assessment year(s) 2001-02 to 2005-06 could be considered/applied while adjudicating the appeals for the assessment year(s)

2006-07 to 2012-13 in order to maintain the consistency.

4. The appeal in ITA No.3314/Del/2013 for AY 2006-07 is, thus, now taken up by us for adjudication.

ITA No.3314/Del/2013 (AY 2006-07)

5. The grounds of appeal raised by the assessee in the memo of appeal filed with the Tribunal for assessment year 2006-07 , reads as under:-

1. That on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming the disallowances made by the Assessing Officer and that the order so passed by the Ld. CIT(A) is bad in law.

2. That on facts and in law the Ld. CIT(A) erred in passing a non- speaking order and confirming the addi