SCHINELER INDIA PVT LTD,MUMBAI vs. DCITRG 15(3) (2) , MUMBAI

ITA 724/MUM/2022Status: DisposedITAT Mumbai31 December 2025AY 2017-18Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal allowed the assessee's claim for deduction under Section 80JJAA, finding that the necessary documentation was provided. It also directed the AO to grant credit for DDT paid by the assessee. The appeal was partly allowed.

What were the facts?

The assessee appealed against the assessment order concerning international transactions related to license fees, management recharge, and IT support. The assessee also claimed deduction under Section 80JJAA and credit for Dividend Distribution Tax (DDT).

What were the issues?

The key issues were the validity of transfer pricing adjustments on international transactions, the allowability of deduction under Section 80JJAA due to alleged non-submission of documents, and the credit for DDT paid.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 92C,Section 92CA(3),Section 37(1),Section 80JJAA,Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “H” BENCH MUMBAI

Before: SHRI PAWAN SINGH & SHRI GIRISH AGRAWAL

Hearing: 08.10.2025Pronounced: 31.12.2025

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the final assessment order passed by National Faceless Assessment Centre, Delhi (NFAC) vide order no. ITBA/AST/S/143(3)/2021-22/1040015716(1) dated 22.02.2022 u/s. 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”) pursuant to the directions of ld. Dispute Resolution Panel-2, Mumbai, (DRP) vide order no. ITBA/DRP/F/144C(5)/2021-22/1039079646(1), dated 25.01.2022, passed u/s. 144C(5), for Assessment Year 2017-18. 2. Grounds taken by assessee are reproduced as under: “Ground I. Legal grounds

2 Schindler India Pvt Ltd. AY 2017-18

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