ORDER

PER CHANDRA POOJARI, ACCOUNTANT MEMBER:

This appeal by assessee is directed against order of DCIT (International Taxation) Circle-2(1), Bengaluru for the assessment year 2017-18 passed u/s 143(3) r.w.s. 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (in short “The Act”). The assessee has raised following concise grounds of appeal:

1. “On the facts and circumstances of the case and in law, the final assessment order passed by the Learned Deputy Commissioner of Income-tax (International Taxation), Circle — 2(1), Bangalore ("Ld. AO"), under section 143(3) read with section 147 and section 144C(13) of the Income-tax Act, 1961 ("the Act") assessing the income of the Appellant at INR instead of returned income of INR 2,34,34,767/- is bad in law.

2. On the facts and in the circumstances of the case and in law, the Hon'ble Dispute Resolution Panel -- 2, Bengaluru (" Ld. DRP") has erred in confirming the validity of initiation of the proceedings under section 147 of the Act in the case of the Appellant merely on the basis of proceedings initiated against Vodafone South Limited ("VSL") under section 201 of the Act without analyzing the facts of present case and jurisprudence in this reg