M/S Idemia Syscom India Private Limited v. Assistant Commissioner of Income Tax, Central Circle- 25
Case brief
What is this about?
Delhi High Court writ petition (W.P.(C) 8463/2025) by Idemia Syscom India Pvt. Ltd. against ACIT, Central Circle-25 concerning transfer pricing: challenge to show cause notice dated 27.05.2025 under section 143(3) of the Income Tax Act, 1961 and draft assessment order under section 144C(1) for Assessment Year 2020-21 alleging departure from the TPO's Arm's Length Price determination. Disposed of on the ground of equally efficacious alternative remedy before the DRP/CIT(A); DRP directed to consider objections on merits bearing in mind Giesecke and Devrient (2024:DHC:2561-DB). Keywords: transfer pricing, ALP, TPO, DRP, section 144C, section 143(3), show cause notice, limitation, jurisdiction, alternative remedy, certiorari, mandamus.
What did the court decide?
No substantive relief. The petition and pending applications were disposed of with observations: the DRP, if objections are filed, to consider them on merits bearing in mind M/s Giesecke and Devrient India Pvt. Ltd.; all rights and contentions of the petitioner reserved; the next date of hearing fixed for 16.07.2025 stood cancelled.