2026 (4) TMI 1186

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....e appeals related to same assessee and similar facts involved in these appeals, hence, the appeals were heard together and disposed of by this common order for the sake of convenience, by dealing with the facts related to assessment year 2017-18. 2. The assessee has raised as many as 8 grounds of appeal, but he argued only ground no. 3 & 3.1, which read as under :- "3. Undated Transfer Pricing order (though mentioned in order as dated 22.01.2021) purportedly passed under section 92CA of the Act is invalid and non-est in law, as same is not in conformity with provisions of the Act. 3.1 Ld. DRP/AO/TPO failed in not appreciating that unauthenticated and undated transfer pricing order (without bearing digital signature) is ....

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....sed/issued by the TPO was released without any signatures. 5. Ld. DR relied upon the order of the TPO and submitted that that the signed order was sent by the registered post to the assessee, so this argument is not tenable. 6. We have heard the rival contentions and perused the records. It is evident from the records that no signed order of the TPO was filed before the Tribunal. It is also evident that DRP in its directions dated 16.6.2022 stated that faceless assessment introduced by the Legislature vide the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act 2020 w.e.f. 1.4.2021 in as much as TP order dated 22.1.2021 was not authenticated, as per the prescribed procedure-e assessment scheme and such finding....