IN THE INCOME TAX APPELLATE TRIBUNAL, ‘J’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER &

SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No.3853/Mum/2025 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 (Assessment Year :2016-17 Assessee by Shri Ajit Jain a/w Shri Akshay Jain & Ms.Archita Singhal Revenue by Shri Pankaj Kumar. CIT DR Date of Hearing 07/01/2026 Date of Pronouncement 12/01/2026 / O R D E R आदेश PER AMIT SHUKLA (J.M):

The present appeal has been preferred by the assessee assailing the Order Giving Effect dated 31 December 2024 passed by the learned Assessing Officer under section 143(3) read with section 254 of the Income Tax Act, 1961 for the Assessment Year 2016–17, pursuant to the directions issued by the Dispute Resolution Panel–2, Mumbai. The appeal arises in the second round of proceedings, the matter having earlier travelled to this Tribunal, which had partly set aside the assessment and restored the issue to the file of the Transfer Prici