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$~10 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 705/2023
PR. COMMISSIONER OF INCOME TAX-1 ..... Appellant Through: Mr Sanjay Kumar, Sr Standing Counsel with Ms Hemlata Rawat, Standing Counsel.
versus
EXPEDITORS INTERNATIONAL (INDIA) PVT. LTD.
..... Respondent Through: Mr Deepak Chopra with Mr Rohan Khare and Mr Priyam Bhatnagar, Advs.
CORAM:
HON'BLE MR. JUSTICE RAJIV SHAKDHER
HON'BLE MR. JUSTICE GIRISH KATHPALIA
O R D E R %
19.12.2023
[Physical Hearing/Hybrid Hearing (as per request)]
We have heard learned counsel for the parties. The following questions of law arise for consideration by the Court: (a) Whether the Income Tax Appellate Tribunal [in short, “Tribunal”] misdirected itself in law and on facts in upholding the deletion of adjustments directed by the Commissioner of Income Tax (Appeals) [in short, “CIT(A)”] vis-à-vis royalty? (b) Whether the Tribunal has erred in law and on facts in deleting the addition made with regard to expenses amounting to Rs. 1,81,052/- incurred by the respondent/assessee on discarded software? ITA 705/2023
1/2 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 27/03/2026 at 12:44:50
List the matter on 23.02.2024. 3. Liberty is given to the counsel for the parties to file additional written submissions on issues that are not common with ITA 698/2023. 4. The additional submissions will not exceed two (2) pages each and will be filed within ten (10) days from today.
RAJIV SHAKDHER, J
GIRISH KATHPALIA, J DECEMBER 19, 2023/pmc
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ITA 705/2023
2/2 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 27/03/2026 at 12:44:50