PR. COMMISSIONER OF INCOME TAX, DELHI-7 vs. TUPPERWARE INDIA PVT. LTD.

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ITA - 391 / 2025HC Delhi09 September 20252 pages
For Petitioner: PUNEET RAI
AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the Revenue's appeal, stating it would follow the fate of a previously dismissed appeal for an earlier assessment year. No perversity was found in the ITAT's findings regarding comparables.

What were the facts?

The Revenue appealed against an ITAT order concerning AY 2014-2015, which followed a previous ITAT decision for AY 2013-14. The High Court noted a prior dismissal of a similar appeal by the same court.

What were the issues?

Whether the High Court should admit an appeal against an ITAT order when a similar appeal for a prior year has already been dismissed. The assessment of comparable companies for transfer pricing purposes.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

$~68 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 391/2025

PR. COMMISSIONER OF INCOME TAX, DELHI-7 .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Gibran, JSC, Mr. Ashvini Kumar, Mr. Rishabh Nangia and Mr. Gibran, Advs.

versus

TUPPERWARE INDIA PVT. LTD. .....Respondent Through: Ms. Tanya and Mr. Rohit Tiwari, Adv.

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

09.09.2025 CM APPL. 56697/2025 1. Exemptions allowed, subject to all just exceptions. 2. The application stands disposed of. CM APPL. 56698/2025 and CM APPL. 56699/2025

3.

For the reasons stated in the applications, the delay of 109 days in filing and 112 days in re-filing, is condoned. 4. The applications are disposed of. ITA 391/2025 5. This appeal by revenue under Section 260A of the Income Tax Act, This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:32:01

1961(the Act) lays a challenge to an order dated 25.07.2024 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No. 8135/Del/2018 filed by the respondent assessee in respect of AY 2014-2015 wherein ITAT has followed its own decision in ITA No. 7580/Del/2017 in respect of respondent assessee for the Assessment Year 2013-14 decided on 01.08.2022. 6. Mr. Puneet Rai, Senior Standing Counsel fairly draws our attention to an order dated 14.03.2024 passed in ITA No. 304/2023 by which the appeal has been dismissed by this Court. Further, Mr. Rai could not point out any perversity in the findings of the ITAT in respect of comparables. 7. In view of the fact that the appeal for the AY 2013-14 has been rejected, this appeal shall also follow the same fate. 8. Accordingly, the appeal is dismissed.

V. KAMESWAR RAO, J

VINOD KUMAR, J SEPTEMBER 9, 2025 ss

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:32:01

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