TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR
In the result, appeal of the assessee is partly allowed for statistical purposes
ITA 430/RAN/2024[2021-22]Status: DisposedITAT Ranchi12 Jun 2025AY 2021-22
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue
Section 35(1)(i). It was a submission that the said R&D led to modifications so as to meet the local emission requirements and as per the agreement the said modifications also belonged to the AE being Cummins
Incorporated.
14
Tata Cummins Vs DCIT
4. We have considered the rival submissions. A specific query was raised