Revenue Appeal Dismissed as No Substantial Question of Law in Transfer Pricing Dispute

PCIT Vs Tupperware India Pvt. Ltd. (Delhi High Court)

The Delhi High Court considered two appeals filed by the Revenue under Section 260A of the Income Tax Act, 1961, challenging a common order dated 12 March 2025 passed by the Income Tax Appellate Tribunal (ITAT) for Assessment Years (AYs) 2015–16 and 2016–17. The High Court first condoned the delays in filing and refiling the appeals and allowed the exemption applications. The substantive challenge concerned transfer pricing adjustments relating to benchmarking of royalty payments and selection of comparables.

During t

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