ORDER

Per Saktijit Dey, VP:

The assessee has filed the present appeal challenging the final assessment order passed u/s. 147 r.w.s. 144 of the Income Tax Act, 1961 (‘the Act’ for short), pertaining to the assessment year (A.Y.) 2016-17, in pursuance to the directions of learned Dispute Resolution Panel (‘ld. DRP’ for short).

2. In ground nos. 1 to 3, the assessee has raised certain legal issues challenging the validity of reopening of assessment u/s. 147 of the Act. However, at the time of hearing, parties agreed to proceed on merits. Hence, at the outset, we deem it appropriate to address the issues arising in ground nos. 4 & 5, which are on merits. If warranted, the legal issues raised in ground nos. 1, 2 and 3 would be taken up at a later stage.

3. In ground no. 4, the assessee has contested the addition made of Rs.1,06,56,120/- u/s. 69 of the Act. Briefly stated, the facts are, the assessee is a non-resident