On writ the assessee contended that the issue was covered by the decision of the Supreme Court in Assessing Officer Circle (International Taxation) v. Nestle SA, (2023) 458 ITR 56 (SC); 2023 SCC OnLine SC 1372 submitting that it would be carrying the matter further in appeal. High Court dismissed the petition by observing that it was bound by the Supreme Court decision.
Schneider Electric Industries SAS v. Dy. CIT (2025) 474 ITR 197 (Delhi)(HC) Societe De Participations Financieries ET Industries v. Dy.CIT (IT) (2025) 474 ITR 197 (Delhi)(HC) Editorial : SLP of assessee dismissed, Societe DE Participations Financieres v Asst. CIT (2025) 474 ITR 199 (SC)
S. 90 : Double taxation relief-Interpretation of agreements-Matter covered by Supreme Court-Writ petition was dismissed.[Art. 226]