ORDER

PER CHANDRA POOJARI, ACCOUNTANT MEMBER:

This appeal by assessee is directed against order of DCIT (International Taxation) Circle-2(2), Bangalore passed u/s 143(3) r.w.s. 144C(13) of the Act. The assessee raised following grounds of appeal:

The grounds mentioned herein are without prejudice to one another:

1. That the order of the Respondent/Assessing Officer (‘AO’ for short) dated 16.10.2023, passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 (‘the Act’), pursuant to the directions of the learned Dispute Resolution Panel (‘the DRP’ for short), is bad in law, contrary to the facts and circumstances of the case and is liable to be set aside.

2. On the facts of the case and in law, the AO erred in making an addition of Rs. 9,64,79,070/- to the total income of the Appellant for assessment year 2021-22.

3. That the DIN purportedly allotted to the directions dated 22.09.2023 issued by the DRP cannot be authenticated on the e-portal of the Income-tax Department and therefore, the directions issued contrary to the Circular No.19/2019 dated 14.08.2019 issued by the Central Board of Di