ORDER : 1. Leave granted. 2. As per the Office Report, service is complete on the sole respondent but no one has entered appearance on behalf of the Respondent – Assessee. 3. Mr. Balbir Singh, learned Additional Solicitor General appearing for the appellant submits that the issue involved in this appeal is squarely answered in favour of the Revenue by a three-Judge Bench of this Court vide Judgment dated 12­10­2022 in “Checkmate Services Private Limited vs. Commissioner of Income Tax­I)” Reported in (2022) SCC Online 1423. 4. In view of the above, the impugned judgment dated 22.03.2019 passed by the High Court of Judicature at Bombay is set aside and the Appeal is allowed in terms of the cited decision.