Income Tax Appellate Tribunal - Delhi
Adobe Systems Software Ireland ... vs Acit/ Dcit, Circle 1(1)(1), New Delhi on 28 March, 2025
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH "D", NEW DELHI
BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER
and
SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER
SA No.222/Del/2025
(in ITA No.1748/Del/2025)
(Assessment Year : 2022-23)
Adobe Systems Software Ireland Limited, vs. DCIT, Circle1(1)(1),
4-6, Riverwalk, Citywest Business Campus, International Taxation,
Saggart, Dublin 24, Ireland. New Delhi.
(PAN : AAHCA7203M)
(APPLICANT) (RESPONDENT)
APPLICANT/ASSESSEE BY: Shri Ravi Sharma, Advocate
REVENUE BY : Shri Rajesh Dhanesta, Sr. DR
Date of Hearing : 28.03.2025
Date of Order : 28.03.2025
ORDER
PER S.RIFAUR RAHMAN, AM:
1. Applicant/Assessee, Adobe Systems Software Ireland Limited (hereinafter referred to as 'the assessee') filed the present stay application sought to stay the demand of Rs.1.64.47.34.570/-/- in AY 2022-23.
2. Heard and perused the record.
3. At the outset, ld. counsel for the assessee submitted that the issue under consideration is fully covered in favour of the assessee. He submitted that if 2 SA No.222/Del/2025 the short early hearing date is given, then the justice may be prevailed and he also requested that till such time, assessee's interest may be protected.
4. On the other hand, ld. DR of the Revenue has no objection for granting of early hearing.
5. In the light of the aforesaid facts and circumstances and considering the issues in hand, we grant early hearing request of the assessee and accordingly, the Registry is directed to fix this case on 03.04.2025 on out of turn basis. The stay application filed by the assessee is dismissed. No coercive action may be initiated till the next date of hearing i.e. 03.04.2025. Both parties are informed in the open court.
6. In the result, the stay application is dismissed on the above terms.
Order pronounced in the open court on this 28TH day of March, 2025 after the conclusion of the hearing.
Sd/- sd/-
(SATBEER SINGH GODARA) (S.RIFAUR RAHMAN)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated: 28.03.2025
TS
Copy forwarded to:
1. Appellant
2. Respondent
3. CIT
4. CIT(Appeals)
5. DR: ITAT
ASSISTANT REGISTRAR
ITAT, NEW DELHI