CBRE Limited v. ACIT

Parties Involved

Facts Summary

This appeal in ITA No.3786/Del/2023 for AY 2021-22 filed by the assessee, CBRE Limited, incorporated in Hongkong, has arisen from the assessment order dated 30th October, 2023 passed by the Assessing Officer under sections 143(3) and 144C(13) of the Income Tax Act, 1961. There were rectification proceedings under section 154 which culminated into a rectification order dated 03.04.2025, wherein the income assessed stood rectified to Rs. 4,96,62,718/-. The assessee has availed the Direct Tax Vivad Se Vishwas Scheme, 2024, and filed necessary declarations with the Department. Form-4 dated 14.07.2025 was issued by the department for full and final settlement of tax arrear under Sub-Section (2) of Section 92 read with Section 93 of Finance (No. 2) Act, 2024.…

Legal Issues

• 1. Whether the appeal should be dismissed due to the assessee availing the Direct Tax Vivad Se Vishwas Scheme, 2024?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

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