DCIT, NEW DELHI vs. M/S. RAYBAN SUN OPTICS INDIA LTD, GURGAON
What did the Tribunal hold?
The Tribunal found that the TPO's application of the CUP method for import of raw materials was not justified due to significant differences and lack of comparable uncontrolled transactions. The Tribunal also found the TPO's application of the RPM method for another transaction to be flawed due to the absence of comparable uncontrolled transactions.
What were the facts?
The Revenue appealed the deletion of transfer pricing adjustments made by the TPO regarding international transactions of Rayban Sun Optics India Ltd. The TPO applied the CUP method for import of raw materials, while the assessee argued for TNMM and presented differences with third-party prices.
What were the issues?
Whether the Comparable Uncontrolled Price (CUP) method was correctly applied by the TPO for import of raw materials, and whether the Resale Price Method (RPM) was correctly applied for another international transaction.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCHES : I-1 : NEW DELHI
Before: SHRI R.S. SYAL, AM & SHRI C.M. GARG, JM
per law.
In the result, the appeal is allowed for statistical purposes.
The order pronounced in the open court on 19.04.2016.
More judgments on Section 92C
- Credit Agricole Corporate and Investment… vs The Assistant Commissioner of Income-Tax…ITA 3453/MUM/2026[2022-23]Status: Disposed8 Oct 2026AY 2022-23
- Credit Agricole Corporate and Investment… vs The Assistant Commissioner of Income Tax…ITA 6805/MUM/2024[2021-22]Status: Disposed8 Oct 2026AY 2021-22
- Tbea Green Energy (India) Private Limited… vs ACIT, Central Circle 1, Vadodara, GujaratITA 592/AHD/2026[2022-2023]Status: Disposed1 Oct 2026AY 2022-2023
- Styrenix Performance Materials Limited… vs Assistant Commissioner of Income Tax…ITA 1066/AHD/2026[2022-23]Status: Disposed1 Oct 2026AY 2022-23
- Styrenix Performance Materials Limited… vs Assistant Commissioner of Income Tax…ITA 1066/AHD/2026[2022-23]Status: Disposed1 Oct 2026AY 2022-23
Recent GST High Court judgments
Search GST case law →- M/S. Nanda Contruction PVT. LTD., Angul vs. Additional Commissioner, GST And Central Excise Commissionerate, SundergarhOrissa · 28 Oct 2026
- M/S Utkal Suppliers,Ganjam vs. Assistant Commissioner Of CT And GST, Ganjam-I Circle,GanjamOrissa · 28 Oct 2026
- M/S Kotdwar Steel Limited vs. Office Of Hte Deputy CommissionerUttarakhand · 28 Oct 2026
- M/S Kotdwar Steel Limited vs. Office Of The Deputy CommissionerUttarakhand · 28 Oct 2026
- M/S Kotdwar Steel Limited vs. Office Of The Deputy CommissionerUttarakhand · 28 Oct 2026