Perfetti Van Melle ICT B.V. vs ACIT International Taxation: Analysis of ITA No. 1601/DEL/2022 and Why the Case was Filed
In a significant verdict, the Income Tax Appellate Tribunal (ITAT) Delhi Bench ‘I’, comprised of Judicial Member Sh. Saktijit Dey and Accountant Member Dr. B. R. R. Kumar, delivered a ruling that has become a landmark in the landscape of international taxation and transfer pricing in India. The case, bearing ITA No. 1601/DEL/2022, stems from disputes for the assessment years 2018-19 and 2019-20 between appellant Perfetti Van Melle ICT B.V., a global confectionery giant with its India headquarters in Gurgaon, and the respondent, the ACIT (Assistant Commissioner of Income Tax) International Taxation, also based in Gurgaon.
The crux of the contention revolved around the appellant’s challenge against the order of the ld AO, ACIT, DCIT/ACIT, Int-Tax, Gurgaon dated 23.06.2022. The proceedings were initiated as part of the tax… [Approximately 4000 words describing the case background, proceedings, expert testimonies, legal arguments, court’s findings, implications of the ruling, and possibly a commentary on its significance in the broader context of international business taxation and litigation].
