2025 (2) TMI 1208

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....Bhatnagar, Adv., Shri Anurag Singhal, Adv. For the Revenue : Shri S. K. Jadhav, CIT DR ORDER PER M. BALAGANESH, A. M : 1. The appeal in ITA No.1627/Del/2022 for AY 2017-18, arises out of the order of the Assessing Officer [hereinafter referred to as 'Id. AO', in short] dated 26.05.2022. 2. At the outset, the ld DR sought an adjournment on the ground that Paper Book has been ....

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....igital platforms within and outside India. 4. The draft assessment order was passed u/s 143(3) read with Section 144C of the Act on 31.03.2021 in which transfer pricing adjustment of Rs. 2,19,68,636/- as suggested by the ld TPO was added to the total income. The assessee filed its objection before the ld DRP. The ld DRP issued direction u/s 144C(5) of the Act on 16.09.2021 upholding the draft a....

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....Delhi Tribunal) wherein it was observed as under :- S. No. Events Nikon Present 1. Directors of DRP issued under section 144(c)5 17.03.2022 08.04.2022 2. Assessment case transferred from Faceless AO to JAO under section 144B(8) of the Act 22.04.2022 Present case transferred on 25.4.2022 3. DRP order received by JAO 02.05.2022 18.05.2022 4. Fina....

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....onto ITBA portal. Intimation letter to DRP order unambiguously shows 27th April 2022 as date of uploading of DRP order. This fact cannot be disputed. Except this critical and relevant information everything else (like when order is visible to AO, date of uploading some document by DCIT/ACIT circle 2 (1) (1) Delhi) has been submitted by Respondents. It is fair to conclude that date of uploading DRP....