IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI B. R. BASKARAN, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No.2248/Bang/2016 Assessment Year: 2012 – 13 M/s. The Himalaya Drug Company Makali, Tumkur Road Bengaluru-562162 Vs. ACIT Central Circle-1(1)

Bengaluru PAN NO : AADFT3025B APPELLANT RESPONDENT Appellant by : Shri Padam Chand Khincha, A.R.

Respondent by : Shri Muzaffar Hussain, D.R.

Date of Hearing : 01.10.2020 Date of Pronouncement : 02.11.2020

O R D E R

PER B.R. BASKARAN, ACCOUNTANT MEMBER:

The assessee has filed this appeal challenging the assessment order dated 20-10-2016 passed by the Assessing Officer for assessment year 2012-13 u/s 143(3) r.w.s.144C of the Income-tax Act,1961 ['the Act' for short] in pursuance of directions given by the ld. Dispute Resolution Panel (DRP).

2. The assessee has filed concise grounds of appeal running into 8 pages and they give rise to the following issues:

a. Assessment order is bad in law, since the AO has issued demand notice along with the draft assessment order.

(Ground No.3)

b. Transfer Pricing adjustment relating to sale of goods to associated enterprises. (Ground Nos. 4 to 8)

c. Transfer Pricing adj