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

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment reserved on: 12.11.2025 Judgment delivered on: 18.05.2026 Judgment uploaded on: As per Digital Signature ITA 656/2019 PR. COMMISSIONER OF INCOME TAX – 1 .....Appellant versus M/S. AMERICAN EXPRESS (INDIA) PVT. LTD. .....Respondent Advocates who appeared in this case For the Appellant : Mr. Debesh Panda, SSC, Ms. Zehra Khan and Mr. Vikramaditya Singh, JSCs. For the Respondent : Mr. Nageswar Rao, Mr. Ravi Lochan, Mr. Parth and Mr. Pratik Rath, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT V. KAMESWAR RAO, J. 1. This appeal has been filed by the appellant under Section 260A of the Income Tax Act, 1961 (“Act”) for the Assessment Year (“AY”) 2009-10 challenging the order dated 03.08.2018 in ITA 2577/Del/2014 passed by the Income Tax Appellate Tribunal (“ITAT”) wherein the ITAT has allowed the assessee’s case. 2. The assessee is American Express (India) Private Limited (AEIPL) 2007. FACTUAL CONTEXT 3. The assessee filed its return of income on 26.09.2009 declaring net income of Rs.1,13,42,21,352/-. Thereafter, the assessee filed its revised income on 29.03.2011. The assessee’s case was select