ORDER

PER MAHAVIR SINGH, VP:

This appeal by assessee is arising out of the final assessment order passed by DCIT/ACIT, TP 1(1), Delhi for the Assessment Year 2017-18 u/s 143(3) r.w.s. 143C (13) r.w.s 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) vide dated 15/07/2022. This order was passed in terms of directions issued by DRP u/s 144C of the Act dated 04/05/2022. The Draft Assessment Order was framed by AO, National Faceless Assessment Centre, Delhi u/s 144C of the Act for Assessment Year 2017-18 dated 26/08/2021 in terms of reference from ACIT, Circle 5(1), Delhi, TPO passed Transfer Pricing Adjustments u/s 92CA of the Act vide order dated 24/01/2021.

3. The first issue in this appeal of assessee as regards to the order of AO passed inconsequence to directions issued by DRP making TP Adjustment of Rs.1,68,25,273/- on account of delay in receiving the trade receivables is a separate international transaction akin to unsecured loan entered by the asses