Idemitsu Lube India Private Limited vs. DCIT
Case No: ITA No.3876/Del/2024
Court: Income Tax Appellate Tribunal, Delhi Bench ‘H’, New Delhi
Date: 1/9/2026
Parties Involved
appellantIdemitsu Lube India Private Limited
respondentDCIT Circle 10(1), New Delhi
Facts Summary
The Assessee, Idemitsu Lube India Private Limited, filed a return of income declaring a total income of Rs. 47,40,50,620/-. The case was selected for ‘Complete Scrutiny’ under CASS. Since the Assessee had entered international transactions and specified domestic transactions with Associate Enterprises, the case was referred to the Transfer Pricing Officer for computation of Arm’s Length Price in relation to International Transactions with Associated Enterprises. The Transfer Pricing Officer pass…
Decision in favour of
Assessee
Legal Issues
- 1. Transfer Pricing ('TP') adjustment amounting to INR 4,53,19,689 in respect of the international transaction pertaining to purchase of raw material.
- 2. Error in computing the margins of comparable companies.
7 more legal issues analysed in this judgement.
Precedents Relied Upon
2 precedents cited in this judgement.