SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -3(3)(1), MUMBAI

ITA 1150/MUM/2025Status: DisposedITAT Mumbai23 January 2026AY 2012-13Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s deletion of transfer pricing adjustments related to Letters of Comfort. Adjustments for financial/corporate and performance guarantees were set aside with directions. The claim for deduction under Section 35DD was confirmed.

What were the facts?

The appeals involved cross-appeals by the assessee and revenue concerning assessment years 2012-2013 and 2013-2014. The core dispute revolved around transfer pricing adjustments related to guarantees and the disallowance of deduction under Section 35DD.

What were the issues?

Whether guarantees issued to associated enterprises constitute international transactions subject to transfer pricing adjustments, and whether expenses for stamp duty on immovable property are deductible under Section 35DD.

Which sections of the Income-tax Act were involved?

Section 92B,Section 35DD,Section 143(3),Section 144C(3),Section 153,Section 43B

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Heard together (2 matters)

ITA No.1149/MUM/2025
ITA No.1217/MUM/2025

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH, MUMBAI SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH, ACCOUNTANT MEMBER (Assessment Year: 2013-2014)

Shapoorji Pallonji and Company Private Limited 1st Floor, 41/44, S. P. Centre, Minoo Desai Marg, Colaba, Mumbai - 400005. Maharashtra. [PAN:AAACS6994C] …………. Appellant Vs Deputy Commissioner of Income Tax, Circle 3(3)(1), Mumbai (now transferred to Deputy Commissioner of Income Tax, Central Circle – (3), Mumbai)

Room No.656, 6th Floor, Aayakar Bhavan, Mumbai – 400020. Maharashtra ………….

Respondent (Assessment Year: 2013-2014)

Deputy Commissioner of Income Tax, Circle 3(3)(1), Mumbai (now transferred to Deputy Commissioner of Income Tax, Central Circle – (3), Mumbai)

Room No.656, 6th Floor, Aayakar Bhavan, Mumbai – 400020. Maharashtra …………. 1st Floor, 41/44, S. P. Centre, Minoo Desai Marg, Colaba, Mumbai - 400005. Maharashtra.

Appellant [PAN:AAACS6994C] ………….

Appearance For the Appellant/Assessee : Shri Rajan Vora, Shri Nikhil Tiwari Ms. Palak Mehta For the Respondent/Depar

The order continues below.

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