TaxTMI 
TaxTMI 
2026 (9) TMI 1310
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....ort "the Act") for the assessment year 2022-23. 2. The assessee has raised the following grounds of appeal:- SI. No Grounds of Appeal Tax effect (in INR) 1. The Order is bad in law and on facts NA 1.1. The assessment order passed by the Ld. Assessment Unit, Income Tax Department ('Ld. AO'), under Section 143(3) read with Section 144C (13) and 144B of the Income- tax Act, 1961 ('the Act'), is without jurisdiction, bad in law and on facts and is in violation of the principles of natural justice. 1.2. The Ld. AO erred in finalizing the assessment based on the original return of income / draft order without taking into consideration the modified return file....
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....s and in law, in making an addition of INR 116,014,519 to the total income of the Appellant, on account of transfer pricing matters despite the following: * The Appellant entered into an Unilateral APA with the Central Board of Direct Taxes ('CBDT') covering the subject year under appeal; and * The Appellant has duly complied with the terms of the APA by filing the Annual Compliance Report on 23 June 2025 and has offered the resultant transfer pricing adjustment as per the terms of the APA (i.e., INR 52,053,304) to tax in the modified return of income filed for the subject year. Accordingly, the impugned adjustment by the Ld. AO and Ld. TPO is contrary to the provisions of section 92CC and 92CD of the Act. &n....
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....ational transaction and computing notional interest on the same. Corporate Tax grounds 6. Non-grant of self-assessment tax of INR 15,559,004 15,559,004 6.1. The Ld. AO has erred in not granting self-assessment tax of INR 15,559,004 paid by the Appellant on 31 May 2025 7. Erroneous levy of interest 2,981,524 7.1. 4 On the facts and circumstances of the case and in law, the Ld. AO has erred in levying interest of INR 2,981,524, without mentioning the section under which interest has been levied. Total tax effect 47,739,062 3. At the outset, the ld. AR of the assessee submitted that the assessee had entered into a....
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.... 4. Aggrieved by the aforesaid order of the AO dated 23.09.2025, the assessee has filed the present appeal before this Tribunal. 5. The ld. D.R. on the other hand fairly conceded that if the AY 2022-23 under consideration is a covered year then the revenue have no objection if the matter is remitted back to the file of the AO to give effect of UAPA. 6. We have heard the rival submissions and perused the materials available on record. Undisputedly, on perusal of the UAPA dated 26.03.2025, we observed that the assessee had entered into a Unilateral Advance Pricing Agreement (UAPA) u/s 92CC of the Act with the Central Board of Direct Taxes (CBDT) on 26th March, 2025 covering Financial year 2021-22 to 2025-26. Considering AY 2022-23 is....