JUDGMENT :

ABHAY AHUJA, J.

1. By this Petition fled under Article 226 of the Constitution of India, 1950, Petitioner is challenging the final Assessment Order dated 6th April, 2021 passed by National e- Assessment Centre, Delhi under Section 143(3) read with Sections 143(3A) and 143(3B) of the Income Tax Act, 1961 (the “IT Act”) and a Notice of Demand under Section 156 of the IT Act, as also Penalty Notice under Section 274 read with Section 270A of the IT Act for the Assessment Year 2017-2018.

2. Petitioner is an Indian Company, incorporated under the Companies Act, 1956. It is submitted that Petitioner is a part of SHL Group, United Kingdom and primarily a trading entity that provides SHL products (psychometric test), assessment, consultancy and training services (‘SHL Solutions’) to clients in India in various industries.

3. Petitioner had fled return of income on 30th March, 2018 declaring a total income of Rs.1,01,31,750/-. Petitioner’s case is that during the Assessment Year 2017-2018, Petitioner had entered into an international transaction with its Associated Enterprise (the “AE”), whereby it was granted a license to market, distribute and deliver the SHL Solutions to clients i