IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “I” BENCH : MUMBAI BEFORE JUSTICE (RETD.) SHRI C.V. BHADANG, PRESIDENT AND SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER Assessment Year : 2023-24 Owens Corning (Singapore) Deputy Commissioner of Pte Ltd., Income Tax (International Tax), C/o. Owens Corning (India) vs. Circle-3(2)(2), Pvt. Limited, 6^th Floor, 7^th Floor, Alpha Building, Kautilya Bhavan, Hiranandani Gardens, Bandra Kurla Complex, Powai, Mumbai-400051.

Maharashtra-400076.

PAN : AABCO5666L (Appellant) (Respondent)

For Assessee : Shri Sandeep Bhalla For Revenue : Shri Krishna Kumar, Sr.DR Date of Hearing : 02-12-2025 Date of Pronouncement : 26-02-2026

O R D E R

PER VIKRAM SINGH YADAV, A.M :

The assessee has filed the present appeal against the final assessment order dated 10-07-2025, passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 („the Act‟), pursuant to the directions issued by the Learned Dispute Resolution Panel-2, Mumbai, ("Ld.DRP"), pertaining to Assessment Year (AY) 2023-24, wherein the assessee has raised the following grounds of appeal:

“1.0 Re: Treating fabrication charges received as 'fees for technical services':

1.1 The Assessing Officer ('AO')/ Dispute Resolu