Archroma International India Private ... vs Deputy Commissioner Of Income Tax ...

ik-172946715 Bombay High Court 16 December 2025 • WRIT PETITION (L) NO.11260 OF 2025 • 20 min read

Judges (2)

Amit S. Jamsandekar Coram B.P. Colabawalla Delivered

Counsel (7)

Abhinav Palsikar Counsel Respondent Harsh Shah Counsel Petitioner J. D. Mistri Counsel Petitioner Paras Savla Counsel Petitioner Pratik Poddar Counsel Petitioner Rajnandini Shukla Counsel Petitioner Sushma Nagraj Counsel Respondent

Parties (2)

Archroma International (India) Private Limited Petitioner Deputy Commissioner of Income Tax, Circle 2(1)(1) Respondent

Case Significance

Archroma International India Private ... vs Deputy Commissioner Of Income Tax... is a Bombay High Court decision dated December 16, 2025 (citation: ik-172946715). Archroma International challenged the income tax department's inaction in giving effect to an ITAT order and DRP directions for AY 2012-13, specifically regarding a transfer pricing adjustment of Rs.10,54,04,393. The court found that the Respondent's attempt to invoke Section 144C(13) for the transfer pricing addition was time-barred as the statutory time frame had already expired. The court declared the transfer pricing adjustment non est and directed recomputation of total income excluding The bench comprised Justices Amit S. Jamsandekar and B.P. Colabawalla. The judgment was delivered by Justice B.P. Colabawalla.

Summary

Archroma International challenged the income tax department's inaction in giving effect to an ITAT order and DRP directions for AY 2012-13, specifically regarding a transfer pricing adjustment of Rs.10,54,04,393. The court found that the Respondent's attempt to invoke Section 144C(13) for the transfer pricing addition was time-barred as the statutory time frame had already expired. The court declared the transfer pricing adjustment non est and directed recomputation of total income excluding the adjustment, with the resulting refund and statutory interest to be paid within six weeks.

What was the outcome of Archroma International India Private ... vs Deputy Commissioner Of Income Tax...?

Archroma International challenged the income tax department's inaction in giving effect to an ITAT order and DRP directions for AY 2012-13, specifically regarding a transfer pricing adjustment of Rs.1...

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (ik-172946715)