IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘E’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTNAT MEMBER ITA No.3532/DEL/2025 [Assessment Year: 2021-22 Amazon Retail India Private Principal Commissioner of Income Limited, Tax, Delhi-1, C.R. Building, ITO, Block E, 14^th Floor, Unit No.1401 Vs I.P. Estate, New Delhi-110002 to 1421 International Trade Tower, Nehru Place, South Delhi, New Delhi-110019 PAN-AAPCA6346P Assessee Revenue Assessee by Shri Ajay Vohra, Sr. Advocate &

Mrs. Deepashree Rao, Advocate, Ms. Ayushu Pragya, Advocate Revenue by Ms. Amish S Gupt, CIT-DR Date of Hearing 20.01.2026 Date of Pronouncement 17.04.2026

ORDER

PER AMITABH SHUKLA, AM, This appeal filed by the assessee is against order dated 28.03.2025 of the Learned Principal Commissioner of Income Tax, Delhi-1[hereinafter referred to as ‘ld. PCIT] arising out of assessment order dated 2012-2022 passed u/s 143(3) of the Income Tax Act, 1961 pertaining to Assessment Year 2021-22. The word ‘Act’ herein this order would mean Income Tax Act, 1961.

2. The assessee has raised following grounds of appeal:-

1. That on the facts and circumstances of the case and in law, the