IN THE INCOME TAX APPELLATE TRIBUNAL, ‘E’ BENCH MUMBAI BEFORE: SHRI SAKTIJIT DEY, VICE PRESIDENT &

SHRI ARUN KHODPIA, ACCOUNTANT MEMBER ITA No. 4964/MUM/2025(AY: 2018–19)

Mahindra & Mahindra Limited Vs. Assessment Unit, Income Tax (as successor to Mahindra Two Department, National Faceless Wheelers Limited which in turn Assessment Centre Local is successor to Mahindra Jurisdictional Assessing Trucks and Buses Limited Officer-

Compnay Deputy Commissioner of Income Mahindra Tower, Second Floor, tax, Circle 2(2)(1), Mumbai.

Corporate Taxation Room No. 545, 5^th Floor, Department, P.K. Kurne Aayakar Bhavan, M.K. Road, Chowk, Worli, Mumbai - Mumbai.

400018 PAN: AAACM3025E of Mahindra & Mahindra Limited AAACM7863L of erstwhile Mahindra Trucks And Buses Limited (Appellant) .. (Respondent Assessee by Shri. Jitendra Trivedi, CA Revenue by Shri. Ritesh Misra, Sr. DR Date of Hearing 23/09/2025 Date of Pronouncement 25/09/2025 Order under section 254(1) of Income Tax Act PER ARUN KHODPIA, ACCOUNTANT MEMBER:

This captioned appeal is filed by the assessee against the order of Commissioner of Income Tax, Appeals CIT(A)/NFAC, Delhi (in short „Ld. CIT(A)‟) u/s 250 of the Income Tax Act, 1961 (in short „th