ORDER आदेश

PER MADHUSUDAN SAWDIA, A.M.:

This appeal is filed by Revenue, feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), Hyderabad (“Ld. CIT(A)”), dated 24.02.2025 for the A.Y. 2021-22.

2. The Revenue has raised the following grounds of appeal :

3. The brief facts of the case are that the assessee is a company engaged in the business of manufacturing and marketing of active pharmaceutical ingredients, generic pharmaceuticals, injectables and related products. The assessee filed its return of income for the Assessment Year 2021–22 on 11.03.2022, declaring total income of Rs.2980,81,43,750/- under the normal provisions of the Income Tax Act, 1961 (“the Act”) and book profit of Rs.4152,70,06,040/- under Section 115JB of the Act. The case of the assessee was selected for scrutiny under CASS, and accordingly, notice under Section 143 (2) of the Act was issued on 27.06.2022. In view of the international transactions entered into by the assessee during the relevant previous year, the case was referred to the learned Transfer Pricing Officer (“Ld. TPO”) for determination of the Arm’s Length Price (“ALP”). The Ld. TPO, vide order dated 30.10.2023, pr