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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Smt. Beena Pillai, J, Shri Girish Agrawal, ACJ
PORTESCAP INDIA PRIVATE LIMITED MUMBAI – Appellant
Versus
DCIT CIRCLE 2(3)(1) MUMBAI – Respondent
| Table of Content |
|---|
| 1. arguments revolve around transfer pricing adjustments and service evaluations. (Para 1 , 4 , 5 , 6 , 7 , 8 , 9) |
| 2. the appellant's business activities and prior assessments are outlined. (Para 2 , 3) |
| 3. the court emphasizes the necessity of establishing service benefits related to valuation. (Para 10 , 11) |
| 4. the final ruling on the appeal's partial allowance is articulated. (Para 12) |
ORDER
Per: Smt. Beena Pillai, J.M.:
The present appeal filed by the assessee arises out of final assessment order dated 23/11/2024 passed by Assessment Unit, for assessment year 2021-22 on following grounds of appeal :
“ The grounds mentioned herein by the Appellant are independent and without prejudice to one another.
1. Ground No.1: General Ground
On the facts and circumstance of the case and in law, the final assessment order dated 23 October 2024, passed by the Assessment Unit, Income-tax Department ('the Ld. AO') under section 143(3) r.w.s 144C(13) r.w.s 1448 of the Income tax Act, 1961 ('the Act') in pursuance to the order of the Additional/ Joint Commissioner of Income-tax, Transfer Pricing, 3(3) Mumbai (the Ld. TPO'), and the directions dated 30 September 2024 passed by the Hon'ble D
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