Revenue Appeal Rejected for Lack of Substantial Question in Transfer Pricing Dispute on Intra-Group Services

PCIT Vs Avery Dennison (India) Pvt. Ltd. (Delhi High Court)

The Delhi High Court dismissed an appeal filed by the Revenue under Section 260A of the Income Tax Act, 1961, challenging an order of the Income Tax Appellate Tribunal dated 05.06.2023. The Tribunal’s order had decided appeals relating to Assessment Years 2012–13 and 2015–16 and had deleted transfer pricing additions concerning payments made for intra-group services. At the outset, the Court condoned delays of 593 days in filing and 146 days in refiling the appeal and disposed of the related applications.

The

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