ORDER

PER SHAMIM YAHYA, ACCOUNTANT MEMBER :

This appeal filed by the assessee is directed against the order of the Assessing Officer dated 26.10.2018 pursuant to the directions issued by the ld. DRP for the Assessment Year 2014-15.

2. Grounds of appeal taken by the assessee read as under :-

“1. That on the facts and circumstances of the case and in law, the order passed by the Learned Joint Commissioner of Income Tax ("Ld. AO") under section 143(3) read with section 144C of the Act is bad in law to the extent of adjustment on account of transfer pricing ("TP") and corporate rate tax issues amounting to INR 21,15,04,079 made in the impugned assessment order.

2. That on the facts and circumstances of the case and in law, the Ld. AO (following the directions of Ld. DRP) erred in assessing the returned income of the Appellant of INR 56,14,77,860 at INR 77,29,81,939.

TRANSFER PRICING GROUNDS:

3. That the Ld. AO [following the directions of Hon'ble Dispute Resolution Panel ("Hon'ble DRP")] erred in proposing to assess the income of the Appellant at INR 77,29,81,940 as against the returned income declared by the Appellant at INR 56,14,77,860 by making an addition of INR 19,71,83,230 holding that