Remanding the matter to the Tribunal, the High Court observed that the Tribunal has followed the decision of the Co-ordinate Bench in case of DCIT v. A. K. A. Logistics (P.) Ltd. (ITA No. 1604 (Kol)) of 2017 dt. 27-2-2019, with no finding recorded as to how such decision would apply to the present case and there has been no discussion on the factual aspect of the case by the Tribunal. Hence, it was held that in the absence of any independent reasoning by the Tribunal with regard to the merits of the matter, it was not possible for High Court to test the correctness of the order passed by the Tribunal, more particularly, when the Court were to ascertain as to whether any substantial question of law arises for consideration. The matter was remanded to the Tribunal for a fresh decision on merits. (AY. 2013-14).