2026 (6) TMI 424

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....directions issued by the learned Dispute Resolution Panel - 1, Bengaluru ("learned DRP") under section 144C(5) of the Act, for the assessment year 2022-23. 2. During the hearing, the learned Authorised Representative ("learned AR"), at the outset in respect of ground no. 9.3 raised in the present appeal, submitted that the final assessment order is bad in law, as the same has not been passed in conformity with the directions issued by the learned DRP, and thus, is in contravention of the provisions of section 144C(13) of the Act. 3. On the other hand, the learned Departmental Representative duly supported the final assessment order passed in the present case. 4. We have considered the submissions of both sides and perused the mater....

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....nt order, in the absence of any order giving effect by the TPO pursuant to the directions issued by the learned DRP regarding recomputation of the transfer pricing adjustment in respect of international transaction pertaining to interest on delayed receivables, proceeded to assess the total income of the assessee equivalent to the total income proposed vide draft assessment order. Further, while computing the book profit of the assessee under section 115-JB of the Act, the AO also did not consider the specific directions of the learned DRP to delete the adjustments proposed to the book profit determined under section 115-JB of the Act. Being aggrieved, the assessee is in appeal before us. 8. During the hearing, the learned AR submitted t....