M/S Fiberhome India (P) Ltd. vs ACIT, Circle-7(1), New Delhi
Case No: ITA No. 6083/Del/2024
Court: Income Tax Appellate Tribunal, Delhi Bench
Date: 1/30/2026
Parties Involved
appellantM/S Fiberhome India (P) Ltd.
respondentACIT, Circle-7(1), New Delhi
Facts Summary
For the assessment year 2021-22, M/S Fiberhome India (P) Ltd. filed its return of income declaring a loss of Rs. 7,03,94,093/-. The case was selected for scrutiny and referred to the Transfer Pricing Officer (TPO) for determining the Arm's Length Price (ALP) of international transactions. The TPO proposed adjustments amounting to Rs. 26,60,76,304/- for import of goods and Rs. 19,95,526/- for interest on External Commercial Borrowings (ECBs). The assessee challenged these adjustments before the D…
Decision in favour of
Assessee
Legal Issues
- 1. Determination of total income by the AO.
- 2. Adjustment of Rs. 24,76,99,067/- to ALP in respect of international transaction relating to import of goods.
4 more legal issues analysed in this judgement.
Precedents Relied Upon
8 precedents cited in this judgement.