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TMI Blog2025 (2) TMI 455X X X X Extracts X X X X X X X X Extracts X X X X ..... are no more res integra and has been decided against the appellant/revenue by the judgements passed in Adobe Systems Software Ireland Ltd.[2025 (1) TMI 1412 - DELHI HIGH COURT] - 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 appeal, the AY pertains to 2020-2021. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ir Bhatia, learned senior standing 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 circumstances of the case, and in law, the Ld. ITAT erred in holding that assessee company does not have existence of dependent PE in India/fixed place P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t that assessee has not discharged its primary 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? 2.4 Whether on the facts and circumstances of the case, and in law, the Ld. ITAT has erred in not following the directions of Supreme Cou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s integra and has been decided against the appellant/revenue by the judgements passed by a Co-ordinate Bench of this Court in Commissioner of Income Tax - International Taxation-1 vs. Adobe Systems Software Ireland Ltd.; 2025 SCC OnLine Del 411 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 yea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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