IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil Kumar, Judicial Member ITA No: 2021/Ahd/2025 Assessment Year: 2016-17 The ACIT M/s. Schaeffler India Ltd.

Circle-1(1)(1), (Formerly known INA Vadodara Vs Bearing India Pvt. Ltd.)

PO-Maneja, Vadodara, Gujarat-390013 PAN: AAACI7163H (Appellant) (Respondent)

Revenue Represented: Shri Sher Singh, CIT-DR Assessee Represented: Shri Milin Mehta, A.R.

Date of hearing : 18-03-2026 Date of pronouncement : 22-04-2026 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

This appeal is filed by the Revenue as against the appellate order dated 05-08-2025 passed by the Commissioner of Income Tax (Appeals)-13, Ahmedabad arising out of the assessment order passed under section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year

2016-17.

2. Brief facts of the case is that the assessee is a Company engaged in the business of manufacturing, development, marketing and distribution of roller bearing, linear bearing systems and engine components. The assessee is one of the companies of Schaeffler Group and in pursuance of the sc