MATRIX CLOTHING PRIVATE LIMITED,GURGAON vs. ACIT, CENTRAL CIRCLE-18, DELHI

ITA 760/DEL/2022Status: DisposedITAT Delhi01 December 2025AY 2017-1819 pages
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What did the Tribunal hold?

The Tribunal held that the TPO's adjustment for guarantee commission was based on a wrong presumption and was flawed. It also ruled that the entire commission paid for the sale of property was allowable as transfer expenses. For Section 14A, the disallowance should be computed only on dividend-bearing investments.

What were the facts?

The assessee company incurred expenses on behalf of its Associated Enterprise (AE) and sought reimbursement. The Transfer Pricing Officer (TPO) made an adjustment on account of guarantee commission, which was upheld by the Dispute Resolution Panel (DRP). The assessee also challenged disallowances related to commission on sale of property and expenses related to dividend income.

What were the issues?

Whether the transfer pricing adjustment for guarantee commission was justified, and whether the entire commission paid for property sale and expenses related to dividend income were allowable.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 14A

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Income Tax Appellate Tribunal, DELHI BENCH “H”: NEW DELHI

Before: SHRI M. BALAGANESH & SHRI VIMAL KUMAR

For Appellant: Ms. Kavita Jha, Sr. Adv, Shri Himanshu Agarwal, Adv, Shri Akash Shukla, Adv
For Respondent: Shri Chetan P. S. Rao, CIT DR
Hearing: 02/09/2025Pronounced: 01/12/2025

PER M. BALAGANESH, A. M.:

1.

The Assessee Matrix Clothing Pvt. Ltd (hereinafter referred to as ‘assessee) by filing the present appeal sought to set aside the impugned order dated 28.02.2022 passed by the Assessing Officer (AO) under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (f

The order continues below.

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