# PR. COMMISSIONER OF INCOME TAX- 2 vs M/S CELEBI DELHI CARGO MANAGEMENT INDIA PVT. LTD.

Court: Delhi High Court
Date: 2025-01-30
Citation: ITA-619/2019 2025:DHC:830-DB
Petitioner: PR. COMMISSIONER OF INCOME TAX- 2
Respondent: M/S CELEBI DELHI CARGO MANAGEMENT INDIA PVT. LTD.

[Official PDF on Delhi High Court website](https://delhihighcourt.nic.in/app/showFileJudgment/YVA30012025ITA6192019_105742.pdf)

## Judgment text (excerpt)

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 30.01.2025 ITA 619/2019 PR. COMMISSIONER OF INCOME TAX- 2 .....Appellant Through: Mr. Indruj Singh Rai, SSC with Mr. Sanjeev Menon, JSC, Mr. Rahul Singh, JSC, Mr. Anmol Jagga & Mr. Prathviraj Day, Advs. versus M/S CELEBI DELHI CARGO MANAGEMENT INDIA PVT. LTD. .....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 JUDGMENT YASHWANT VARMA, J. (Oral) 1. This appeal is directed against the order of the Income Tax Appellate Tribunal1 dated 23 October 2018 and came to be admitted on the following question of law: - “(a). Whether the ITAT was legally justified in quashing the order passed by the PCIT-2 under Section 263 of the Act which had been passed as the order of the Assessing Officer ["AO"] was erroneous and prejudicial to the interest of revenue?” 2. The principal issue which arises for our consideration is 1 Tribunal ITA 619/2019 19612. Although the respondent-assessee was held eligible to claim benefits under that provision by the Assessing Officer3, the Principal Commissioner of Income Tax4 while ex

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