(1.) Present appeals have been filed challenging the order dtd. 8/11/2019 passed by Income Tax Appellate Tribunal in SA No.1005/Del/2019 in ITA No. 6949/Del/2017 for the Assessment Year 2013-14 and in SA No.1004/Del/2019 in ITA No. 901/Del/2017 for the Assessment Year 2012-13, respectively.
(2.) Admittedly, the earlier appeals filed by the appellant-Revenue on similar grounds were dismissed by this Court relying on the judgment of this Court in Pepsi Foods (P.) Ltd. vs. Assistant Commissioner of Income-tax, [2015] 376 ITR 87 (Delhi).
(3.) Recently, the Supreme Court has dismissed the Special Leave to Appeal, being Deputy Commissioner of Income-tax vs. Pepsi Foods Ltd., [2021] 126 taxmann.com 69 (SC), filed by the Revenue. The relevant portion of the judgment passed by the Supreme Court is reproduced hereinbelow:-