New Delhi: SML Mahindra Ltd (formerly SML Isuzu) said it has received an appeal-effect order from the Income Tax Department, imposing total transfer pricing adjustments of ₹16.41 lakh for Assessment Year 2022-23. The order, issued by the Assistant Commissioner of Income Tax (Transfer Pricing), follows directions from the Dispute Resolution Panel (DRP) dated November 22, 2025, which had initially proposed adjustments of ₹9.92 lakh.
In a regulatory filing, the company said the tax authority has disputed the arm’s length pricing and methodology used for the corporate guarantee fee paid to its associated enterprise, as well as the method adopted for determining arm’s length price in the manufacturing segment.
The assessing officer may also examine initiation of penalty proceedings under Section 270A of the Income Tax Act.
SML Mahindra said it will file an appeal against the order and has downloaded the communication from the Income Tax portal on December 10, 20 25.