IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 6083/DEL/2024 Assessment Year: 2021-22

O R D E R

PER Ms. MADHUMITA ROY, JM:

The instant appeal, filed by the assessee, is directed against the Assessment Order dated 29.10.2024 [DIN: ITBA/AST/S/143(3)/2024-25/1070024806(1)], passed by the Assessment Unit, Income Tax Department, under Section 143(3) r.w.s. 144C(13) read with Section 144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), pursuant to the directions of the Dispute Resolution Panel (“DRP”) under Section 144C(5) of the Act for the Assessment Year 2021-22.

2. Grounds of appeal raised by the assessee are as under:

“1. That the learned Assessment Unit, Income Tax Department ("AO") has erred both in law and on facts in determining total income of the appellant company at Rs. 17,93,00,500/- as against declared loss of Rs. 7,03,94,093/-in an order of assessment dated 29.10.2024 under section

143(3)/144C(13) read with section 144B of the Act.

2. That the learned AO/TPO/DRP has erred both in law and on facts in making an adjustment of Rs. 24,76,99,067/- to arms le