$~28 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 127/2026 CM APPL. 10258/2026 CM APPL. 10259/2026 COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-3, DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Ashvini Kumar, Mr. Gibran, JSCs, and Mr. Rishabh Nangia, Adv. versus M/S VERITAS STORAGE SINGAPORE PTE LTD .....Respondent Through: Mr. Tarun Gulati, Sr. Adv. with Mr. Nikhil Gupta, Mr. Rochit Abhishek, Advs. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR % 12.05.2026 O R D E R 1. By way of instant appeal, the Income Tax Department has challenged the order dated 22.08.2025 passed by the Income Tax Appellate Tribunal Delhi “D” Bench (ITAT) (hereinafter referred to as “the Tribunal”) in ITA No. 1913/Del/2023. 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. 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 16/05/2026 at 12:09:31 3. Mr. Tarun Gulati, learned Senior Counsel for the respondent-assessee submitted that the said judgment of the Tribunal rendered in TSYS Card Tech Ltd. (supra) 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. 4. Mr. Puneet Rai, learned Senior Standing Counsel for the appellant is not in a position to dispute the aforesaid position. 5. 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. 6. The appeal along with the pending applications is also disposed of. DINESH MEHTA, J VINOD KUMAR, J MAY 12, 2026/dd 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 16/05/2026 at 12:09:31