ORDER

Per Smt. Beena Pillai, JM:

The aforesaid appeals have been filed by the assessee against the final assessment orders passed u/s 143(3) r.w.s. 144C(13) of the Act, in pursuance of the directions issued by the Ld. DRP for the respective assessment years under consideration. The details of the final assessment orders passed by the Ld. AO for each assessment year are tabulated as under:

Since common issues are involved in all these appeals, they were heard together and are being disposed of by way of this consolidated order for the sake of convenience.

2. At the outset, both sides fairly submitted that identical issues arising in the present appeals have been consistently considered by the Coordinate Benches of this Tribunal in assessee’s own case across various assessment years. In particular, reliance was placed on the orders passed in:

• I.T.A. No. 1615/Mum/2022 (A.Y. 2017–18) & I.T.A. No. 2259/Mum/2022 (A.Y. 2018–19), order dated 22/09/2025;

• I.T.A. No. 4713/Mum/2023 (A.Y. 2021–22), order dated 27/02/2025;

• I.T.A. No. 7779/Mum/2012 (A.Y. 2008–09), order dated 16/06/2025.

2.1. It was further submitted that the issues involved in all these years are identical and arise on similar facts and circumstances. In particular, it was pointed out that the issues have been dealt with in detail by the Coordinate Bench in assessee’s own case for I.T.A. Nos. 2153/Mum/2014 & 2179/Mum/2014 (A.Y. 2009–10), order dated 07/06/2024.

2.2. It was thus jointly agreed that the findings rendered by the Coordinate Bench for A.Y. 2009–10 may be followed and applied mutatis mutandis to the other assessment years under consideration, as the facts, issues, and findings of the authorities below remain identical.

3. On identical facts, the assessee has furnished a consolidated chart tabulating the issues along with corresponding grounds raised for the years under consideration in the following manner:

We have heard the submissions advanced by both sides and perused the records placed before this Tribunal.

4. Issue No. 1: General Ground

The grounds raised under this issue are general in nature and do not call for any specific adjudication. Accordingly, the same are treated as not requiring separate consideration.

5. Issue No. 2: Taxability on Cash vs. Accrual Basis

We have perused the submissions advanced by both sides in light of the records placed before this Tribunal. This issue pertains to the taxability of income on cash basis vis-à-vis accrual basis. It is observed that the Coordinate Bench in assessee’s own case for A.Y. 2009–10 has dealt with this issue in detail. The relevant findings of the Tribunal are as under:-

“77. Ground No.1 of Revenue’s appeal refers to direction of the ld. DRP to tax royalty in FTS on receipt basis which according to department shall be on accrual basis.

78. The assessee is a non-resident Company, incorporated in Germany, having taxable income in India. With regard to FTS and royalty is has shown income on receipt basis as per the India Germany DTAA. The issue before us is, whether the income of the assessee is to be taxed on receipt basis as against accrual basis. The ld. AO has relied u