IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A” NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A No.1890/Del/2025 Assessment Year: 2022-23 IMAX THEATRE SERVICES LTD. Vs THE ASSISTANT COMMISSIONER OF

2525, Speakman Drive, Mississauga, INCOME TAX, Circle 2(1)(1), Ontario, Foreign, Canada, International Taxation, Canada 999999. Civic Centre, Minto Road, PAN No. AACC15822K New Delhi, Delhi 110002.

Appellant Respondent Assessee by Shri S.K. Aggarwal, CA & Shri Himanshu, CA Revenue by Shri M.S. Nethrapal, CIT DR Date of hearing: 06.05.2026 Pronouncement on 13.05.2026

O R D E R

PER SANJAY AWASTHI, ACCOUNTANT MEMBER:

1. This appeal arises from Ld. AO’s order u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereafter as “the Act”) dated 24.01.2025. This order itself incorporates the directions of Ld. DRP dated 31.12.2024.

1.1 The assessee is a tax resident in Canada and as per the India-Canada DTAA (hereafter as “the DTAA”), it holds a valid Tax Residency Certificate issued by the Canadian Government. The assessee is engaged in the business of providing maintenance services of Theatre Systems (IMAX Theatre Systems) globally, includ