IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘D’ NEW DELHI BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No.7615/Del/2025 ( A.Y 2020-21)

Assistant Commissioner of Vs Degolyer and Macnaughton Income Tax, Corporation, Suite 800, East Dr. S. P.M. Civic Centre, Minto 5001 Spring valley Raod, Road, SKD Basti, Press Dallas Texas Texas US 75244, Enclave, Ajmeri Gate, 999999, foreign USA New Delhi-110002 PAN: AADCD4948E (APPLICANT)

(RESPONDENT)

Appellant by Sh. Amit Arora & Vishal Misra, CAs Respondent by Sh. Vikram Singh Sharma, Sr. DR Date of Hearing 09.04.2026 Date of Pronouncement 30.04.2026 ORDER PER YOGESH KUMAR, U.S. JM:

The present appeal is filed by the Revenue against the order of Ld. Commissioner of Income Tax (Appeals)-Delhi-42, (‘Ld. CIT(A)’ for short), dated 06/10/2025 for the Assessment Year 2020-21.

2. Brief facts of the case as mentioned in the order of the CIT(A) are as under: -

“2.1 The appellant is a non-resident foreign company incorporated in the USA and is engaged in providing a wide range of petroleum consulting services to clients worldwide in the oil and gas industry. It filed the return of income on 05.02.2021 de