Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1962/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Precision Camshafts Ltd., V Assessment Unit, Income Tax E-102/103, Akkalkot Road, S Department (National Midc, Solapur – 413006. Faceless Assessment Center), Maharashtra. Jurisdiction Details : Pne- C(1), Range 63, Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 17/06/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Assessment Unit, Income Tax Department Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 25.07.2024, Emanating From Order Of Dispute Resolution Panel U/S.144C(5) Of The Act For A.Y.2020-21

928 of the Act disregarding the fact that the provision of corporate guarantee to the subsidiary was intended to facilitate an acquisition of two companies in the European jurisdiction by the Appellant. and consequently the guarantee was in the nature of shareholder services and thus a separate charge is not warranted, not appreciating the fact that the Appellant has entered