ORDER

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Assessing Officer (hereinafter referred to as Ld. 'AO') passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2021-22 dated 28.10.2024, which has been passed after considering the directions of the DRP u/s 144C(5) of the Act, dated 30.09.2024.

2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:

“1. That on the facts and circumstances of the case & in law, the final assessment order dated October 28, 2024, passed by the National Faceless Assessment Centre, Assessment Unit, Income Tax Department (the Ld. AO), making an addition of Rs. 62,97,51,510/- to the returned income pursuant to the directions of the Ld. Dispute Resolution Panel-II, Delhi ('Ld. DRP') is bad in law and, therefore, liable to be set aside.

2. That on the facts and circumstances of the case & in law, the order passed under section 92CA(3) of the Act by Ld. Deputy Commissioner of Income Tax, Transfer Pricing-1, Kolkata (Ld. TPO') on September 12, 2023, proposing a downward adjustment of Rs. 182,23,39,293, which wa