$~63 & 64 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 825/2019 DEPUTY COMMISSIONER OF INCOME TAX-5(2) .....Appellant Through: Mr. Siddhartha Sinha, SSC. versus CELEBI DELHI CARGO MANAGEMENT .....Respondent Through: Ms. Kavita Jha, Sr. Adv. with Mr. Himanshu Aggarwal, Adv. 64 + ITA 879/2019 DEPUTY COMMISSIONER OF INCOME TAX-5(2) .....Appellant Through: Mr. Anurag Ojha, SSC with Mr. V.K Saksena, JSC, Ms. Hemlata Rawat, JSC, Mr. Dipak Raj & Mr. Subham Kumar, Adv. versus CELEBI DELHI CARGO MANAGEMENT .....Respondent Through: Ms. Kavita Jha, Sr. Adv. with Mr. Himanshu Aggarwal, Adv. CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR % 30.01.2025 O R D E R Parties are ad idem that the judgement pronounced by us in Pr. Commissioner of Income Tax-2 v M/s Celebi Delhi Cargo Management India Pvt. [2025:DHC:830-DB] would cover the issue in the instant appeals. 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 15/02/2025 at 12:07:48 In light of the above, we allow the appeals and answer the question framed in the negative and in favour of the appellant. The order of the Income Tax Appellate Tribunal dated 08 February 2019 is consequently set aside and that of the Principal Commissioner of Income Tax restored. YASHWANT VARMA, J. HARISH VAIDYANATHAN SHANKAR, J. JANUARY 30, 2025/DR 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 15/02/2025 at 12:07:48