IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D’: NEW DELHI BEFORE SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER AND SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER ITA No.2842/Del/2025, A.Y. 2020-21 Hasbro SA Dy. Commissioner of Rue Emile Boechat 31, Income Tax (International

2800 Delemont, Vs. Tax), Switzerland, Circle-1(1)(1), Switzerland Delhi PAN: AAFCH6585F (Appellant) (Respondent) Appellant by Sh. Manish, Advocate Respondent by Sh. Vikram Singh Sharma, Sr.DR Date of Hearing 14/01/2026 Date of Pronouncement 21/01/2026 O R D E R PER RAJ KUMAR CHAUHAN (J.M.):

1. This appeal is directed against the order dated 01st Feb, 25 of passed by Learned Commissioner of Income Tax (Appeals) -42, Delhi [hereinafter referred to as the “CIT(A)”], passed under section 250 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] wherein rectification order dated 15.06.2024 u/s 154 of the Act by ACIT (CPC), Bengaluru was upheld and disallowance of TDS claim of Rs. 21,14,675/- was confirmed.

2. The facts in brief are that the appellant is a foreign company having registered office located in Switzerland. During the A.Y. 2020-21, the appellant has earned income of INR 2,11,46,750/- from which tax of IN