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TMI Blog2025 (2) TMI 456X X X X Extracts X X X X X X X X Extracts X X X X ..... of law raised in this appeal is no more res integra and has been decided against the appellant/revenue by the judgement passed in Adobe Systems Software Ireland Ltd [2023 (10) TMI 699 - ITAT DELHI] and batch matters. The parties in the aforesaid batch matters and the present appeals are the same, except that, in those appeals, the AYs were for the years from 2013 till 2017, whereas in the present ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax Appellate Tribunal (ITAT) in respect of the respondent/Assessee for the Assessment Year (AY) 2021-22. 4. At the outset, Mr. Ruchir Bhatia, learned senior standing counsel counsel appearing for the revenue brings attention of this Court to para 2 of the appeal wherein substantial questions of law have been framed by the appellant, which reads thus:- "2.1 Whether on' the facts and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ry onus to provide the information and date required for ascertaining the proportion of receipts of the PE which were not covered under the Transfer Pricing study report or not subjected to arm's length pricing? 2.3 Whether on the facts and circumstances of the case, and in law, the Ld. ITAT has erred in not following the directions of Supreme Court in case of DIT v. Morgan Stanley Co where ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es in the aforesaid batch matters and the present appeals are the same, except that, in those appeals, the AYs were for the years from 2013 till 2017, whereas in the present appeal, the AY pertains to 2021-2022. 6. Predicated thereon, he candidly submits that no substantial question of law is made out in the present appeal. 7. In view of the aforesaid, this Court is of the considered opinion tha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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