IN THE INCOME-TAX APPELLATE TRIBUNAL, MUMBAI “I” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND(cid:1)

SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER DCIT, Room No. 627, 6^th Floor, vs. Sita Information Networking Kautilya Bhavan, BKC Bandra East, Computing USA INC, Finance Mumbai-400051. Directors Office Sita INC USA Suite

900 3100 Cumberland BLVD Atlanta FA 30339 Foreigin United States, USA-99999.

PAN/GIR No: AAVCS5544D (Appellant) (Respondent)

Assessee by Shri Ketan Ved & Shri Nianad Patade Revenue by Shri Satya Pal Kumar (CIT DR)

Date of Hearing 16.03.2026 Date of Pronouncement 29.04.2026 O R D E R PER BIJYANANDA PRUSETH, AM:

This appeal filed by the assessee emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act’) by the Commissioner of Income-Tax (Appeals), 58, Mumbai [in short, ‘CIT(A)’], dated 11.09.2025 for the assessment year (AY) 2022-23.

2. The grounds of appeal raised by the assessee are as under:

“1. Whether on the facts and circumstances of the case, the Ld. CIT (A) has erred in not appreciating that the receipt of Rs.79,47,67,624/-from Passenger Systems Solutions ('Passenger Services') is taxable in the hands of the assessee as