SML Mahindra Limited Receives Income Tax Appeal Effect Order with ₹16.41 Lacs Adjustments
SML Mahindra Limited received an appeal effect order from the Income Tax Department with total adjustments of ₹16.41 lacs for AY 2022-23, following transfer pricing disputes over corporate guarantee fees and manufacturing segment pricing methods. The company plans to appeal the order while potential penalty proceedings under section 270A may be examined.

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SML Mahindra Limited has disclosed receiving an appeal effect order from the Income Tax Department with total adjustments of ₹16.41 lacs for Assessment Year 2022-23. The company communicated this development to stock exchanges on December 10, 2025, in compliance with regulatory disclosure requirements.
Income Tax Order Details
The Assistant Commissioner of Income Tax - Transfer Pricing, Delhi issued the appeal effect order on December 9, 2025, following directions from the Dispute Resolution Panel under section 144C(5). The company received and downloaded the order from the Income Tax portal on December 10, 2025, at 3:12 PM.
| Parameter: | Details |
|---|---|
| Issuing Authority: | Assistant Commissioner of Income Tax - Transfer Pricing, Delhi |
| Order Date: | December 9, 2025 |
| Assessment Year: | 2022-23 |
| Total Adjustments: | ₹16.41 lacs |
| Receipt Date: | December 10, 2025 at 3:12 PM |
Transfer Pricing Disputes
The Income Tax Authority has raised disputes regarding two key areas of the company's transfer pricing practices. The primary concerns involve the Arms Length Price and methodology adopted by SML Mahindra Limited for payment of Corporate Guarantee fees to Associated Enterprises. Additionally, the authority has questioned the method used for ascertaining Arms Length Price in the company's manufacturing segment operations.
Previous Developments
This latest order represents a continuation of ongoing transfer pricing proceedings. Earlier, the Dispute Resolution Panel had issued directions under section 144C(5) on November 22, 2025, for the same assessment year with adjustments of ₹9.92 lacs. The company had previously communicated these developments to stock exchanges on November 22, 2025, through letter number SML/SEC/2025-26-083.
| Timeline: | Event | Amount |
|---|---|---|
| November 22, 2025: | DRP Directions under 144C(5) | ₹9.92 lacs |
| December 9, 2025: | Appeal Effect Order | ₹16.41 lacs |
| December 10, 2025: | Company Disclosure | - |
Potential Penalties and Company Response
The order indicates that the Assessing Officer may examine the initiation of penalty proceedings under section 270A of the Income Tax Act, 1961. This provision typically relates to penalties for underreporting of income or misreporting of facts in tax returns.
SML Mahindra Limited has stated its intention to file an appeal against this order, indicating the company's disagreement with the tax authority's assessment and adjustments. The company continues to maintain compliance with regulatory disclosure obligations by promptly informing stock exchanges of these developments.
Regulatory Compliance
The disclosure was made pursuant to Regulation 30(2) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, read with Clause 20 of Para A of Part A of Schedule III. This ensures transparency regarding material developments that could impact the company's financial position or operations.
Historical Stock Returns for SML Mahindra
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -1.83% | +11.69% | +24.80% | +100.62% | +141.75% | +695.31% |














































