DY. COMMISSIONER OF INCOME TAX-5(2)(1), MUMBAI vs. JSW JAIGARH PORT LIMITED, MUMBAI

ITA 5144/MUM/2024Status: DisposedITAT Mumbai17 June 2026AY 2016-1711 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the CIT(A)'s order deleting a transfer pricing adjustment of Rs. 18,40,00,000 for operation and maintenance services. The assessee filed a cross-objection regarding the assessment order's validity.

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision, stating that a transaction accepted as arm's length for one associated enterprise cannot be treated differently for the other. The Revenue's grounds were dismissed.

What were the issues?

Whether the CIT(A) was justified in deleting the transfer pricing adjustment for services received by the assessee from its associated enterprise. Whether the principle of corresponding or mirror transactions applies in transfer pricing.

Which sections of the Income-tax Act were involved?

Section 92C,Section 92(2A),Section 92(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “K” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI ANIKESH BANERJEE

For Appellant: Shri Gaurav Kabra, Shri Bhagirath Ramawat (SR DR)
Hearing: 10/06/2026

M/s. JSW Jaigarh Port Limited M/s. JSW Jaigarh Port Limited TA No. 5144/MUM/2024 & CO No. 14/MUM/2025

PER OM PRAKASH KANT, AM PER OM PRAKASH KANT, AM

This appeal by the appeal by the Revenue and cross-objection

The order continues below.

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