IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’, NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER ITA No.5356/Del/2024 Assessment Year: 2021-22 Kunshan Q Tech DCIT Microelectronics (India) Vs Central Circle – 30 Pvt. Ltd. Delhi B-4, ECOTECH-1, Extension, Greater Noida Gautam Buddha Nagar, Uttar Pradesh 201310 PAN No.AAHCK4396H (APPELLANT) (RESPONDENT)

Appellant by Sh. Pavan Ved, Advocate Sh. Mohit Gupta, CA Respondent by Sh. Dharm Veer Singh, CIT DR Sh. Wageesh Shrotriya, ACIT-

CC-30 Date of hearing: 15/12/2025 Date of Pronouncement: 20/01/2026 ORDER PER C.N. PRASAD, JM:

This appeal is filed by the assessee against final assessment order dated 29.10.2024 for the A.Y.2021-22 passed u/s.143(3) r.w.s. 144C (13) in pursuance to the directions of the DRP dated 13.09.2024 passed u/s.144C(5) of the IT Act. The assessee in its appeal raised the following grounds :-

“1. That on the facts, law and in the circumstances of the case, the orders passed by the Assessing Officer (AO) [Draft Assessment Order and Final Assessment Order), Transfer Pricing Officer (TPO) as well as the Dispute Resolution Panel (DRP) are bad in law, violative of principles o