COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-3, DELHI vs. VERITAS STORAGE SINGAPORE PTE LTD.

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ITA/516/2026HC DelhiDLHC01029280202610 July 2026Author: HON'BLE MR. JUSTICE DINESH MEHTA,HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA2 pages
AI SummaryDismissed

What did the High Court hold?

The Delhi High Court rejected the appeal filed by the Commissioner of Income Tax. The Court noted that the ITAT's impugned order was based on its earlier judgment in TSYS Card Tech Ltd. v. DCIT. Crucially, this ITAT decision had been affirmed by a Division Bench of the Delhi High Court itself in a prior judgment dated 16.07.2024 in ITA No. 165/2024. The revenue's counsel conceded that they were unable to dispute this established legal position. Consequently, the High Court found no grounds to interfere with the ITAT's order and dismissed the appeal. The operative direction was the rejection of the appeal.

What were the facts?

The Commissioner of Income Tax (International Taxation-3), Delhi (the appellant/revenue) has appealed against an order dated 30.12.2025 passed by the Income Tax Appellate Tribunal (ITAT), Delhi 'D' Bench. The ITAT's order in ITA No. 2026/Del/2025 was based on its prior decision in the case of TSYS Card Tech Ltd v. DCIT, Circle-3(1)(1), International Taxation, New Delhi (ITA No. 2006/Del/2022). This ITAT decision was subsequently affirmed by a Division Bench of the Delhi High Court in ITA No. 165/2024, titled The Commissioner of Income Tax – International Taxation-3 v. TSYS Card Tech Ltd., vide a judgment dated 16.07.2024. The revenue's counsel was unable to dispute this position.

What were the issues?

1. Whether the ITAT's order dated 30.12.2025 in ITA No. 2026/Del/2025, which relied on its earlier decision in TSYS Card Tech Ltd v. DCIT, is sustainable in law? Assessee's contentions: The judgment does not record any specific contentions made by the assessee, Veritas Storage Singapore Pte Ltd. Revenue's contentions: The revenue, represented by the Commissioner of Income Tax, International Taxation-3, Delhi, did not dispute the position that the ITAT's order was based on its prior ruling in TSYS Card Tech Ltd., which had been affirmed by the Delhi High Court. Therefore, the revenue was not in a position to challenge the ITAT's order.

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
$~14 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 516/2026 & CM APPL. 42683/2026 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-3, DELHI .....Appellant Through: Mr. Puneet Rai, SSC with Mr.Ashvini Kr. & Mr. Rishabh Nangia, JSCs versus VERITAS STORAGE SINGAPORE PTE LTD. .....Respondent Through: CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE RAJNEESH KUMAR GUPTA

O R D E R %

10.07.

2026

1.

By way of instant appeal, the Income Tax Department has challenged the order dated 30.12.2025 passed by the Income Tax Appellate Tribunal Delhi “D” Bench (hereinafter referred to as ‘the Tribunal’) in ITA No. 2026/Del/2025. 2. A perusal of the impugned order passed by the Tribunal shows that the Tribunal has relied upon its earlier judgment in the case of TSYS Card Tech Ltd v. DCIT, Circle- 3 (1)(1), International Taxation, New Delhi rendered in ITA No. 2006/Del/2022, which judgment has been affirmed by a Division Bench of this Court vide a judgment dated 16.07.2024 titled as The Commissioner of Income Tax – International Taxation-3 v. TSYS Card Tech Ltd. rendered in ITA No. 165/2024. 3. Mr. Puneet Rai, learned Senior Standing Counsel for the appellant is 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 14/07/2026 at 11:30:06

not in a position to dispute the aforesaid position.

4.

The present appeal is, therefore, rejected in the light of the judgment of this Court in ITA No. 165/2024 rendered on 16.07.2024, whereby the view of the Tribunal in the case of TSYS Card Tech Ltd. (supra) has been affirmed.

5.

The appeal along with the pending applications is also disposed of. DINESH MEHTA, J RAJNEESH KUMAR GUPTA, J JULY 10, 2026 kk 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 14/07/2026 at 11:30:06

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