IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, I: NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.5929/Del/2024 [Assessment Year: 2021-22]

Swatch Group (India) Private Deputy Commissioner of Income Limited, Tax, 4th Floor, Rectangle-I, Plot No. D- Vs Circle 22(2), 4, Saket District Centre, C.R. Building, I.P. Estate, Delhi, New Delhi -110017. 110002.

PAN- AAFCS7516R Assessee Revenue Assessee by Shri Rohit Tiwari, Adv.

Ms. Tanya, Adv.

Revenue by Shri Dharm Veer Singh, CIT(DR)

Date of Hearing 09.01.2026 Date of Pronouncement 14.01.2026

ORDER

PER BRAJESH KUMAR SINGH, AM:

This appeal has been preferred by the assessee against the Final Assessment Order dated 29.10.2024 passed by the Learned Assessing Officer (AO) under Section 143(3) read with Sections 144C(13), r.w.s. 144B of the Income-tax Act, 1961 (“the Act”), pursuant to the directions of the Hon'ble Dispute Resolution Panel (DRP) order dated 09.09.2024 for the Assessment Year 2021-22.

2. Brief facts of the case: The Swatch Group Limited is based in Switzerland and the ultimate holding company of the Swatch Group, world's largest manufacturer and distributor of luxury