PCIT v. Fujitsu India (P.) Ltd. (2025) 304 Taxman 657 (SC) Editorial : PCIT v. Fujitsu India (P.) Ltd(2024) 296 Taxman 197 (Delhi)(HC)

S. 92C : Transfer pricing-Arms’ length price– Avoidance of tax -International transaction-Gross delay of 434 days in filing SLP had not been satisfactorily explained by revenue- SLP of revenue dismissed.[Art. 136]

High Court  held that RPM was most appropriate method for determining ALP of international transaction in case of distribution and marketing activities especially when goods are purchased from AEs and there were sales to unrelated parties without any processing and value addition.Since gross delay of 434 days in filing SLP had not been satisfactorily explained by revenue, SLP of revenue  was  dismissed. (AY. 2012-13, 2013-14)

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