Authority: High Court of Judicature at Bombay

Order Date: 17 September 2026

Case Overview

  • Parties: Appellant – Marriott International Inc.; Respondent – The Deputy Commissioner of Income Tax (International Taxation)-3(2)(1).
  • Counsel: For the appellant – Mr. Paras Savla, Mr. Harsh Shah, Mr. Pratik Poddar, Ms. Rajnandini Shukla. For the respondent – Ms. Ashita Aggarwal, Mr. Subir Kumar.
  • Nature of Proceeding: Income Tax Appeal No.3312 of 2018 concerning the assessment year 2010‑11, originally decided by the Income Tax Appellate Tribunal.
  • Background: A related appeal, Income Tax Appeal (L) No.4135 of 2024, filed by the Department against the same Tribunal order, was withdrawn by the Department.
  • Court’s Observation: The withdrawal of the connected appeal extinguishes the basis for the present appeal, rendering it non‑viable for further consideration.

Final Outcome

  • The Bombay High Court disposed of the appeal, ordering that it stand closed.
  • No costs were awarded to either party.
  • Refund of court fees was ordered as per the applicable Rules.
  • Any substantial question(s) of law that may arise from this matter are to remain open for determination in an appropriate proceeding.

Topics: Tax Litigation, Court Order