J U D G M E N T

PURUSHAINDRA KUMAR KAURAV, J.

1. The present writ petition, at the instance of the assessee, seeks to assail the impugned order dated 24 April 2021 passed under Section 144C read with Sections 143(3) and 144B of the Income Tax Act, 1961 [“Act”], whereby, the Assessing Officer [“AO”] made an adjustment of INR 25,58,68,79,196/-, to the total income of the assessee.

2. The brief facts, which are relevant to the present controversy reveal that the assessee is engaged in providing software and information technology enabled services. On 01 April 2016, the assessee‟s mobile security division got demerged into the Giesecke & Devrient MS India on a going concern basis. Both the assessee and Giesecke & Devrient MS India are the wholly owned subsidiaries of Giesecke & Devrient MS GmbH, a company incorporated in Germany. The assessee filed its Income Tax Return [“ITR”] for assessment year [“AY”] 2017-18 on 30 November 2017 declaring an income to the tune of INR 18,15,98,120/-. Thereafter, the assessee‟s case was picked up for scrutiny and notices under Sections 143(2) and 142(1) of the Act were issued to the assessee.

3. It may be noted that since the assessee had entered into int