INTERNATIONAL MANAGEMENT GROUP (UK) LIMITED Vs. COMMISSIONER OF INCOME TAX-2, INTERNATIONAL TAXATION, NEW DELHI

JUDGEMENT

(1.) This set of appeals instituted by the International Management Group (UK) Limited [hereinafter to be referred as "IMG'], impugn the decisions rendered by the Income Tax Appellate Tribunal [1] on appeals spanning Assessment Years [2] 2010-11 to 2018-19. The appeals had been formally admitted on the following three principal questions of law: -

(2.) The said questions as they arise in this batch have been set out succinctly in a tabular statement which forms part of the written submissions tendered by the appellant and is extracted hereinbelow:- <FRM>JUDGEMENT_37_LAWS(DLH)7_2024_1.html</FRM>

(3.) As would be manifest from a perusal of the aforesaid table, the solitary distinctive feature concerning ITA 218/2017 and ITA 381/2019 is the fact that the Indian Premier League [3] in those years had been held outside India and more particularly in South Africa and the United Arab Emirates respectively.