THE COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, NEW DELHI vs M/S EXPEDITORS INTERNATIONAL OF WASHINGTON INC.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision: 06.10.2025 ITA 491/2025 THE COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, NEW DELHI .....Appellant Through: Mr. Puneet Rai, Sr. Standing Counsel with Mr. Ashvini Kumar, Mr. Rishabh Nangia and Mr. Gibran, Advs. versus M/S EXPEDITORS INTERNATIONAL OF WASHINGTON INC. .....Respondent Through: Mr. Rohan Khare and Mr. Priyam Bhatnagar, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR V. KAMESWAR RAO, J. (ORAL) CM APPL. 62662/2025(Exemption) 1. Exemption is allowed, subject to all just exceptions. 2. The application stands disposed of. CM APPL. 62663/2025 (Condonation of delay of 420 days in re-filing) 3. For the reasons stated in the application, the delay of 420 days in re- filing the appeal is condoned. 4. The application is disposed of. 5. The challenge in this appeal under Section 260A of the Income Tax Act, 1961 is to an order dated 09.02.2024 passed by the learned Income Tax Appellate Tribunal (‘ITAT’) in ITA No. 2855/Del/2023 pertaining to the Assessment Year (‘AY’) 2021-22. 6. We find on findings from paragraph 6 onwards, the learned ITAT has allowed the appeal in favour of the asse