आदेश/ORDER

PER S. R. RAGHUNATHA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is directed against the final assessment order passed by the DCIT, Central Circle 1(4), Chennai, u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter the ‘Act’) for the assessment year 2021-22 dated 29.10.2024 in pursuant to the directions of the Dispute Resolution Panel-2, Bengaluru dated 09.09.2024.

2. The assessee has raised the following issues:-

Ground No.1: General

Ground No.2: General ground on Transfer Pricing Issues

Ground No.3: Transfer Pricing Issue – Downward adjustment of Rs.45,28,07,087/- on Marketing services fees.

Ground No.4: Transfer Pricing Issue – Upward adjustment of Rs.1,64,75,839/- on account of interest on trade receivables from AEs.

Ground No.5: Transfer Pricing Issue – Upward adjustment of Rs.53,58,144/- on account of fees chargeable on the Corporate Guarantee given by the Assessee to its AEs.

Ground No.6: General ground on Corporate Tax Issues

Ground No.7: Corporate Tax Issue – Disallowance of depreciation claimed @ 40% on ATM machines by restricting it to 15% chargeable on ‘Plant & machinery’ amounting to Rs. 46,56,30,577/-

Ground No.8: Corporate Tax Issue – Dis