RDER

PER S. RIFAUR RAHMAN, AM :

1. This appeal has been filed by the assessee against the final assessment order dated 19.10.2023 passed u/s 143(3) r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions of the Ld. Dispute Resolution Panel (DRP)/TPO vide order dated 13.09.2023 for Assessment Year 2021-22.

2. Brief facts of the case are, assessee filed its return of income for AY 2021-22 on 31.01.2022 declaring income of Rs.10,63,65,830/-. The case was selected for complete scrutiny under CASS due to large refund claimed by the non-resident. Accordingly, notice under section 143(2) and 142(1) of the Act along with questionnaire were issued and served on the assessee. In response, assessee filed its responses to various notices issued during the assessment proceedings.

3. The background of the assessee is, it is incorporated on 06.03.2015 as Limited Liability Company under the laws of Luxembourg. It is a Category II – Foreign Portfolio Investor registered with the Securities and Exchange Board of India (SEBI). Assessee is a subsidiary of SC Lowy Primary Investments Limited and it invests in securities. It has invested in SCCL Property Sor