IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 2038/MUM/2025 (AY : 2022-23)

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Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER;

1. This appeal by assessee is directed against the addition in assessment order passed under section 143(3) r.w.s. 144C(13) dated 28.01.2025, passed in pursuance of direction of DRP dated 24.12.2024 for A.Y. 2022-23. The assessee has raised following grounds of appeal:

“1. General Ground

1.1 The final assessment order ("Impugned Order") passed by the Assistant Commissioner of Income-tax (International Taxation)-4(3)(1) ("Ld. AO") under Section 143(3) read with Section 144C(13) of the Income-tax Act, 1961 (the "Act"), pursuant to the directions issued by the Learned Dispute Resolution Panel 2, Mumbai (the "Ld. DRP") under section 144C(5) of the Act, suffers from legal defects such as, but not limited to, being passed in violation of principles