JUNGHEINRICH LIFT TRUCK INDIA PRIVATE LIMITED,MUMBAI vs. ASSESSMENT UNIT, NATIONAL E ASSESSMENT CENTRE- DELHI, DELHI

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ITA 4260/MUM/2024Status: DisposedITAT Mumbai21 May 2025AY 2020-2021Bench: MS. PADMAVATHY S (Accountant Member), SHRI RAJ KUMAR CHAUHAN (Judicial Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the assessee's submissions regarding foreign exchange loss were not considered properly and restored the issue to the AO for fresh adjudication. Regarding reimbursement of expenses, the Tribunal also restored the issue to the Transfer Pricing Officer (TPO) to allow the assessee to substantiate the expenditure.

What were the facts?

The assessee claimed foreign exchange loss and reimbursement of expenses. The Assessing Officer (AO) disallowed the foreign exchange loss and determined the Arm's Length Price (ALP) of reimbursement of expenses as NIL. The Dispute Resolution Panel (DRP) upheld the AO's findings.

What were the issues?

Whether the foreign exchange loss is allowable and whether the reimbursement of expenses is at Arm's Length Price.

Which sections of the Income-tax Act were involved?

Section 43AA,Section 145(2),Section 92C,Section 270A,Section 271AA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “K” BENCH MUMBAI

For Appellant: Shri Ajit Jain / Shri Siddesh Chaugule, Shri Rishab Parekh, Ld. ARs
For Respondent: Shri Kiran Unavekar, Sr. DR
Hearing: 05.03.2025Pronounced: 21.05.2025

आदेश की प्रतितिति अग्रेतिि/Copy of the Order forwarded to : अपीलाथी / The Appellant 1. प्रत्यथी / The Respondent. 2.

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