IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA SHRI PRADIP KUAMR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER (Assessment Year 2020-2021)

DIC Fine Chemicals Private Limited, UB-03, Mani Tower, 31/41, Binova Bhave Road, Sahapur, Kolkata - 700038 [PAN: AACCD6812G] ……..…...…………….... Appellant vs.

DCIT, Circle 11(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata - 700069 ................................ Respondent Appearances by:

Assessee represented by : Akkal Dudhewala, AR Department represented by : Praveen Kishore, CIT (DR)

Date of concluding the hearing : 16.06.2025 Date of pronouncing the order : 23.06.2025

O R D E R

PER SANJAY AWASTHI, ACCOUNTANT MEMBER

1. The present appeal arises from order u/s 143(3), r.w.s. 144C(13), r.w.s. 144B of the Income Tax Act, 1961 (hereafter “the Act”). In this case, the assessee purchased raw material from certain Associated Enterprises (AEs) and also from some third parties. The finished product is seen to have been sold to the assessee’s group concerns. As per the Transfer Pricing (TP) documents furnished for the AY 2020-21, the assessee was seen to have entered into certain international transactions with AEs. T