आदेश/ORDER 

Per Shri D.S.Sunder Singh, Accountant Member :

This appeal filed by the assessee is directed against the order of Deputy Commissioner of Income Tax, Hyderabad, dated 31.10.2018 passed u/s 143(3) r.w.s 144C of the Income Tax Act for the Assessment Year 2015- 16 and stay application is filed by the assessee. Since the main appeal is taken up for hearing, the stay application filed by the assessee is dismissed in limine.

The assessee filed appeal raising the following grounds of appeal:

1. On the facts and in the circumstances of the case and in law, the Ld. Transfer Pricing Officer i.e the Deputy Commissioner of Income-tax - Circle - 2(1), Hyderabad (hereinafter referred to as the Ld. TPO’) and the Ld. AO under the directions issued by Hon’ble DRP, erred in making an addition to the Appellant’s total income of INR 4,60,53,538 (based on the provisions of Chapter X of the Income-Tax Act, (’the Act’) and the said additions being wholly unjustified are liable to be deleted.

2. On the facts and in the circumstances of the case and in law, the Ld. TPO erred and the Hon’ble DRP further erred in upholding/ confirming the action of the Ld. TPO in incorrectly including / selecting the f