IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.3623/Mum/2025 (Assessment Year : 2021-22)

DCIT, Circle – 3(4), Room No.559, 5^th Floor, Aayakar Bhavan, M.K. Road ............... Appellant Mumbai - 400020 v/s Bajaj Auto Limited, 2nd Floor, Baja Bhawan 226, ……………… Respondent Jamnalal Baja Marg, Nariman Point, Mumbai - 400021 PAN : AADCB2923M Assessee by : Ms. Vasanti Patel Revenue by : Shri Satyaprakash R. Singh, CIT-DR Date of Hearing – 10/09/2025 Date of Order - 16/10/2025

O R D E R

PER SANDEEP SINGH KARHAIL, J.M.

The Revenue has filed the present appeal against the impugned order dated 13/03/2025, passed under section 250 of the Income-tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year

2021-22.

2. In this appeal, the Revenue has raised the following grounds: –

“i) Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that expenditures on dies and moulds are revenue expenditure and not capital expenditure, ignoring the fa