$~7 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 363/2025 CM APPL. 54182/2025 GE NUOVO PIGNONE S.P.A NOW KNOWN AS NUOVO PIGNONE INTERNATIONAL SRL .....Appellant Through: Mr. Sachit Jolly, Sr. Advocate, Ms Viyushti Rawat, Ms Sherry Goyal, Mr. Denash Jain and Mr. Sarthak Abrol, Advs. Versus DY. COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, DELHI I & ANR. .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR % 23.02.2026 O R D E R 1. Mr. Sachit Jolly, learned Senior Advocate, fairly submitted that the substantial questions of law as mentioned/proposed being question no. A to F has been decided against the appellant, in ITA 491/2019, while substantial question of law no. G to I stands covered in by the judgment passed in Writ Petition no. 6494/2019, both decided on 19.09.2024. 2. Hence, all the questions stand decided as indicated above. The appeal thus, stands dismissed. 3. Needless to observe that disposal of the present appeal shall not influence the decision of the Income Tax Appellate Tribunal in relation to This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/02/2026 at 15:24:32 the miscellaneous application, which the appellant has already filed in relation to the interest under Section 234B of the Income Tax Act, 1961, which question we have not decided. 4. The pending application(s) stand disposed of. DINESH MEHTA, J VINOD KUMAR, J FEBRUARY 23, 2026/dd This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 25/02/2026 at 15:24:32