IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘A’: NEW DELHI.

BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI ANUBHAV SHARMA, JUDICIAL MEMBER (Assessment Year: 2020-21)

Adani Tracks Management Vs. AO-CPC (Bangalore)

Service Limited (Formerly known (Jurisdictional AO-DCIT, as Adani Tracks Management Circle-3(1), Gurgaon.

Service Pvt. Ltd.) (also formerly known as Surgula Rail Corridor Pvt. Ltd., Plot No. 83, Sector 32 Adani House, \

Institutional Area, Gurgaon, Delhi-110006.

(PAN: AAOCS5350A)

(APPELLANT) (RESPONDENT)

ASSESSEE BY : Dhrunal Bhatt, C.A.

REVENUE BY : Shri Ajay Arora, Sr. DR Date of Hearing : 04.11.2025 Date of Order : 21.01.2026

ORDER

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

The assessee has filed appeal against the order of the Learned Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi [“Ld. CIT(A)”, for short] dated 20.02.2023 for the Assessment Year 2020-21, wherein the assesse has raised following grounds:-

“1.In law and in the facts and circumstances of the case, the learned CIT(A) has erred in rejecting the claim of appellant for Rs. 6,51,894/-towards gratuity expense when such claim is duly allowable in view of provisions of secti