IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, H: NEW DELHI BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.- 5286/Del/2024 [Assessment Year: 2021-22]

Honda Trading Corporation India DCIT/ ACIT, Pvt. Ltd., Circle 10(1), Delhi Assessment F-10, Manish Twin Plaza, Plot No. Vs Unit, Income Tax Department, CR.

3, Sector-4, Dwarka- 110078. Building IP Estate, New Delhi-

110002.

PAN- AABCH5556J Assessee Revenue Assessee by Shri Nageshwar Rao, Adv. (virtual), Shri Parth, Adv.

Revenue by Shri Ravinder Yadav, Sr. DR Date of Hearing 13.11.2025 Date of Pronouncement 04 .02.2026

ORDER

PER BRAJESH KUMAR SINGH, AM, This appeal has been preferred by the assessee against the Final Assessment Order dated 23.10.2024 passed by the 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) dated

25.09.2024 for the Assessment Year 2021-22.

1.1 Ground no. 1 and 2 of the appeal are reproduced as under:

“1. Impugned order is time barred, invalid and bad in law as reference made to Ld.

TPO does not appear to be in accordance wi