2026 (7) TMI 396

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....961, (in short 'the Act'). 2. The assessee has raised the following grounds in appeal: 1. On the facts and in the circumstances of the case and in law, the order passed by the Ld. AO under section 143(3) r.w.s. 144C(13) r.w.s.144B based on order issued by the Ld. TPO is bad in law. 2. On the facts and in the circumstances of the case and in law, the order passed by the Ld. AO erred in making an addition of Rs. 6,87,56,670/- towards transfer pricing on the basis of the order passed by the Ld. TPO on 16-10-2025 without considering the fact that the said order dated 16-10-2025 stands rectified by the Ld. TPO under section 154 vide its order dated 10-11-2025 wherein the adjustment determined in the original order dated 16-1....

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....termine the "Arm's Length Price" in respect of the international transactions undertaken by the assessee during the F.Y.2021-22 relevant to the A.Y.2022-23. In the T.P. study the assessee claims the net operating margin earned by Jinfei India to its operating revenue in F.Y.2021-22 is 6.38%. The Ld. TPO opted the TNMM method and after applying the filters selected the four comparables. The Ld. TPO passed order on 14-01-2025 proposing TP adjustment of Rs.  6,87,56,670/- to the taxable income. The Assessing Officer issued the draft assessment order in the compliance of the Ld. TPO order. Being aggrieved the draft assessment order the assessee filed the objections before the Hon'ble DRP. The Hon'ble DRP after considering the submissions m....