TECH MAHINDRA LTD,MUMBAI vs. DCIT CIR 2(3), MUMBAI

ITA 7487/MUM/2012Status: DisposedITAT Mumbai24 August 2026AY 2008-0956 pages
AI SummaryPartly Allowed

What were the facts?

The assessee, Tech Mahindra Ltd., appealed against an assessment order for AY 2008-09. The appeal involved several grounds, including issues related to transfer pricing, characterization of payments, disallowance of depreciation, mark-to-market profits, and disallowance under Section 14A.

What did the Tribunal hold?

The Tribunal directed the AO to grant TDS credit to the extent evidenced by TDS certificates. Several additional grounds raised by the assessee were dismissed as not pressed, academic, or decided against the assessee.

What were the issues?

The primary issues involved the correctness of transfer pricing adjustments, the characterization of various payments, the allowability of depreciation and expenses, and the computation of deduction under Section 10A.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 32,Section 37,Section 10A,Section 14A,Section 234D,Section 220(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: SMT. BEENA PILLAI, HON’BLE & SHRI JAGADISH, HON’BLE

For Respondent: Shri. Ajay Chandra, CIT DR
Pronounced: 24/08/2026

PER SMT. BEENA PILLAI, JUDICIAL MEMBER:

Present appeal filed by assessee arises out of the final assessment order framed u/s 143(3) r.w.s. 144C(13) of the Act by the ACIT, Rg. – 2(3), Mumbai, dated 31/03/2008, for A.Y. 2008- 09, on the following grounds of appeal:-

“Adjustment / Addition to Total Income

ITA 7487/MUM/2012

1 On the facts and in the circumstances of the case and in law, the learned Transf

The order continues below.

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