PR. COMMISSIONER OF INCOME TAX-1 vs. M/S EXPEDITORS INTERNATIONAL (INDIA) PVT. LTD.

$~5 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 696/2023

PR. COMMISSIONER OF INCOME TAX-1 ..... Appellant Through: Mr Sanjay Kumar, Sr Standing Counsel with Ms Hemlata Rawat, Standing Counsel.

versus

M/S 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)] 1. We have heard learned counsel for the parties. The following questions of law arise for consideration by the Court: (a) Whether the 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 amounting to Rs.1,81,052/- concerning disallowance of bank guarantee commission charges and cash management service charges? ITA 696/2023

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 13:32:27

RAJIV SHAKDHER, J

GIRISH KATHPALIA, J DECEMBER 19, 2023/pmc

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ITA 698/2023

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 13:32:27