5 IN HIGH COURT OF DELHI AT NEW DELHI ITA 993/2019, CM APPLs. 53587/2019 & 53588/2019 PR. COMMISSIONER OF INCOME TAX-6. Appellant Through: Mr. Ruchir Bhatia, Senior Standing Counsel with Mr. Shlok Chandra and Ms. Madhura M. N., Advocates. versus MICROSOFT INDIA (R & D) PVT. LTD. Respondent Through: Mr. Nageshwar Rao and Mr. Sherry Goyal, Advocates. CORAM: HON'BLE MR. JUSTICE VIPIN SANGHI HON'BLE MR. JUSTICE SANJEEV NARULA ORDER 02.03.2020 1. question sought to be urged by Revenue in this appeal under Section 260A pertains to extension of stay beyond 365 days. This issue is now squarely covered by Division Bench ruling of this Court in Pepsi Foods Pvt. Ltd. vs. ACIT 376 ITR 87. Therefore, no question of law arises for consideration in this appeal. 2. This appeal and applications are dismissed. VIPIN SANGHI, J SANJEEV NARULA, J MARCH 02, 2020 v Signature Not Verified Digitally Signed By: SAPNA SETHI Signing Date:06.03.2020 12:06:34 Pr. Commissioner of Income-tax-6 v. Microsoft India (R & D) Pvt. Ltd