PCIT v. Sumitomo Corporation India Pvt. Ltd. (2024)462 ITR 98 (Delhi)(HC)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Net margin method-Identical with earlier years-No substantial question of law. [S.260A]

Dismissing the appeals of the Revenue the Court held that the issues in the appeals for the assessment years 2012-13 and 2013-14 were pari materia with those that arose in the assessment year 2007-08 to assessment year 2010-11. The Department did not prefer an appeal against such order dated October 22, 2018 passed by the Tribunal and the order had attained finality. The Tribunal had, in sum, sought to re-examine the issue, in the light of the directions contained therein. Therefore, the appeals for the assessment years 2012-13 and 2013-14 did not give rise to any question of law.(AY.2012-13, 2013-14)