IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH BEFORE SHRI INTURI RAMA RAO, AM AND SHRI RAHUL CHAUDHARY, JM Assessment Year: 2021-22 Apollo Tyres Ltd. .......... Appellant

3rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [PAN: AAACA6990Q]

vs.

ACIT, Corporate Circle-1(1), Kochi ......... Respondent Assessee by: Shri Abraham Joseph Markos, Adv.

Revenue by: Shri Sanjit Kumar Das, CIT-DR Date of Hearing: 20.08.2025 Date of Pronouncement: 10.09.2025

O R D E R

Per: Inturi Rama Rao, AM This appeal filed by the assessee is directed against the final assessment order dated 24.10.2024passed u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of Income Tax Act, 1961 (hereinafter "the Act") for Assessment Year (AY) 2021-22.

2. Brief facts of the case are that the appellant is a company incorporated under the provisions of Companies Act, 1956. It is engaged in the business of manufacture and sale of tyres, tubes and dealing in flaps. The return of income for AY 2021-22 was filed on

03.03.2022 declaring Nil income and also reported book profit under MAT of Rs. 1088,40,84,655/-. The assessee company also reportedthe certaininternational transactions from AE in from 3CEB. 3. On noticing the above inter