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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Shri Pawan Singh, JM, Smt. Renu Jauhri, AM
DSV Air & Sea Private Limited – Appellant
Versus
Commissioner of Income-tax, Circle 3(1)(1) – Respondent
| Table of Content |
|---|
| 1. assessee's appeal against assessment order detailing income discrepancies and adjustment concerns. (Para 1 , 1 , 2) |
| 2. challenges regarding selection of comparables and adjustments not aligning with the operational profile. (Para 3 , 4 , 6 , 7 , 10) |
| 3. court's rationale on the importance of functional comparability in transfer pricing. (Para 8 , 9 , 12) |
| 4. final directives on adjustments, highlighting the balance between comparability and the operational nature of the assessee. (Para 11 , 13 , 14 , 15 , 16) |
1. This appeal by assessee is directed against the additions made in assessment order passed under section 143(3) r.w.s. 144C(13) dated 31/05/2024, passed in pursuance of direction of Dispute Resolution Panel (DRP) under section 144C(5) dated 27/05/2024. The assessee has raised the following grounds of appeal:-
“GROUNDS OF APPEAL
Based on the facts and in the circumstances of the case and in law, DSV Air & Sea Private Limited ('the Appellant' or 'DSV India') respectfully craves leave to prefer an appeal under Section 253 of the Income Tax Act, 1961 ('Act") against the order dated on 30 May 2024 passed by the Additional Joint/Deputy/Assistant Commissioner of Income-t
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