IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No. 2969/Del/2017, A.Y.2009-10 Pioneer India Electronics Dy. Commissioner of Income Pvt. Ltd., Tax, Circle-2, 216, 2^nd Floor, Time Tower, Vs. Income Tax Office, M. G. Road, Gurgaon Udyog Vihar, PAN: AAECP8368H HSIIDC Building, Gurgaon (Appellant) (Respondent)

Appellant by Shri Nageswar Rao, Advocate Respondent by Sh. Bhopal Singh, Sr. DR Date of Hearing 23/06/2025 Date of Pronouncement 19/09/2025

ORDER

PER AVDHESH KUMAR MISHRA, AM This appeal of the assessee for the Assessment Year (‘AY’) 2009-10 is directed against the order dated 13^th March, 2017 of the Commissioner of Income Tax (appeal)-2, Gurgaon [‘CIT(A)’].

2. The assessee has raised following grounds:

“1. The Commissioner of Income Tax (Appeals), Gurgaon ("CIT (A)) based on the order passed by the Deputy Commissioner of Income Tax, Circle 2, Gurgaon (learned AO) and Additional Director of Income Tax (Transfer Pricing-II (1) ('learned TPO) under Section 92CA(3) of the income-Tax Act, 1961 ('the Act"), have erred in law and on facts of the case in framing the assessment