IMPERIAL JEWELS,MUMBAI vs. DCIT-24(1), MUMBAI

ITA 5941/MUM/2025Status: DisposedITAT Mumbai29 June 2026AY 2022-237 pages
AI SummaryPartly Allowed

What were the facts?

The assessee appealed against the NFAC's order for AY 2022-23, challenging transfer pricing adjustments and consequential disallowance of deduction under Section 10AA. The Tribunal noted that the grounds raised were identical to those in the assessee's own case for AY 2021-22.

What did the Tribunal hold?

The Tribunal followed its previous decision for AY 2021-22, finding that the foundational requirements for adjustment under Section 80-IA(10) were not established. The transfer pricing adjustment and consequential disallowance were not sustained.

What were the issues?

Whether transfer pricing provisions apply to the transactions and whether the conditions for adjustment under Section 80-IA(10) were met by the revenue.

Which sections of the Income-tax Act were involved?

Section 10AA,Section 92A,Section 92BA,Section 92CA,Section 80-IA(10),Section 92F,Section 234A,Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: HON’BLE BEENA PILLAI & HON’BLE JAGADISH

For Respondent: Shri. Pravin Salunkhe, Sr.DR
Pronounced: 29/06/2026

PER BEENA PILLAI, JUDICIAL MEMBER:

Present appeal filed by the assessee arises out of the order dated 29/08/2025 passed by NFAC, Delhi [hereinafter referred to as “Ld.CIT(A)”] for A.Y. 2022-23, on the following grounds of appeal:-

“1. The orders of the Dispute Resolution Panel ('DR'), Transfer Pricing Officer ('TPO') and Assessing Officer ('AO') are without juri iction, bad in law and ought to be cancelled as the reference to TPO and downwa

The order continues below.

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