TIMEX GROUP INDIA LTD.,NEW DELHI vs. ADDI. CIT SPL.RANGE-9, NEW DELHI

ITA 7527/DEL/2019Status: DisposedITAT Delhi28 November 2025AY 2014-15Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)6 pages
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What did the Tribunal hold?

The Tribunal found merit in the assessee's ground regarding the ad-hoc disallowance of miscellaneous expenses and allowed it. The Tribunal also found the assessee's explanation for the sales turnover mismatch plausible and directed the deletion of the addition, allowing the ground. However, the disallowance under Section 40(a)(i) of the Act was upheld as the assessee failed to provide substantiating material.

What were the facts?

The assessee, Timex Group India Ltd., appealed against the CIT(A)'s order regarding disallowance of miscellaneous expenses and a mismatch in sales turnover. The Revenue's appeal was concerning transfer pricing issues. Both parties agreed that transfer pricing issues were settled under APA.

What were the issues?

Whether the ad-hoc disallowance of miscellaneous expenses and the addition on account of sales turnover mismatch were justified, and whether the disallowance under Section 40(a)(i) was correct.

Which sections of the Income-tax Act were involved?

Section 40(a)(i)

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Heard together (2 matters)

ITA No.7527 /DEL/2019
ITA No.7599 /DEL/2019

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

आयकर अपीलीय अिधकरण िद"ी पीठ “डी”, िद"ी "ी िवकास अव"थी, "ाियक सद" एवं "ी मनीष अ"वाल, लेखाकार सद" के सम" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “D”, DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRI MANISH AGARWAL, ACCOUNTANT MEMBER आअसं.7527 /िद"ी/2019 (िन.व. 2014-15) ITA No.7527 /DEL/2019 (A.Y 2014-15) Timex Group India Ltd., 106-07, AmbadeepBuidling, Kasturba Gandhi Marg, New Delhi 110001 ...... अपीलाथ"/Appellant PAN: AAACT-0773-C बनाम Vs. Additional Commissioner of Income Tax, Special Range-9, Block-B, First Floor, Pratyakshkar Building, ....."ितवादी/Respondent Civic Centre, New Delhi 110002 आअसं. 7599 /िद"ी/2019 (िन.व. 2014-15) ITA No.7599 /DEL/2019 (A.Y 2014-15) Additional Commissioner of Income Tax, Special Range-9, Block-B, First Floor, Pratyakshkar Building, ...... अपीलाथ"/Appellant Civic Centre, New Delhi 110002 बनाम Vs. Timex Group India Ltd., 106-07, AmbadeepBuidling, Kasturba Gandhi Marg, New Delhi 110001 ....."ितवादी/Respondent PAN: AAACT-0773-C

Assessee by : Shri Vikrant A Maheshwari, Advocate (Through VC) Department by : Shri Vikram Singh Sharma, Sr. DR सुनवाई क" ितिथ/ Date of hearing : 09/10/2025 घोषणा क" ितिथ/ Date of pronouncement : : 28/11/2025

The order continues below.

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