CIT Vs Sutherland Global Services Inc. (Madras High Court)
The Madras High Court dismissed the Revenue’s appeals, noting that the issues raised were identical to those decided earlier by the Court on 10.06.2025 in connected matters. In those cases, the Court had upheld the ITAT’s decision setting aside assessment orders because the directions issued by the Dispute Resolution Panel were invalid due to the absence of a Document Identification Number (DIN). Finding the facts and legal position to be the same, the Court applied the same reasoning and dismissed the present appeals. As costs had already been imposed in the earlier matters, no separate order on costs was passed, and the interim applications were closed.
FULL TEXT OF THE JUDGMENT/ORDER OF MADRAS HIGH COURT
Mr. Karthik Ranganathan, the learned counsel for the appellant/revenue, submitted that the above two appeals impugn a common order dated 22.12.2023 that was set aside by this Court in respect of another assessee in T.C.A.Nos.80, 81 and 82 of 2025 by an order dated 10.06.2025.
2. We find that in the above appeals, the orders were confirmed by this Court since the ITAT had set aside the assessment orders as the directions of the DRP were invalid for want of a DIN number. The facts are similar in this case and the reasons assigned by us for dismissal of the aforesaid appeals would be applicable to the instant appeals also.
