INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER (Assessment Year: 2018-19)

Massimo Dutti India Pvt. Ltd, Vs. ACIT, Unit No. 1 (Office 1) 8^th Floor, Circle-1(1), Ambience Island, NH-8, Gurgaon Gurugram, Hayana-122 002 (Appellant) (Respondent)

PAN: AAJCM0103G Assessee by : Shri Ravi Sharma, Adv Ms. Shruti Khimta, Adv Ms. Kashish Gupta, CA Revenue by: Shri S. K. Jadav, CIT DR Date of Hearing 11/09/2025 Date of pronouncement 08/12/2025

O R D E R

PER M. BALAGANESH, A. M.:

1. The Assessee Massimo Dutti India Pvt. Ltd. (hereinafter referred to as „assessee) by filing the present appeal sought to set aside the impugned order dated 19.07.2022 passed by the Assessing Officer (AO) under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (for short „the Act‟) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 07.06.2022 u/s 144C(5) and order of TPO dated 15.09.2022 passed u/s 92CA(3).

2. The Ground No. 1 raised by the Assessee is general in nature and does not require any specific adjudication.

3. The Ground Nos. 2 and 3 raised by the Assessee are challenging the Transfer P