IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE Ms SUCHITRA KAMBLE, JUDICIAL MEMBER And SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER (Assessment Year: 2022-23)

CA(Singapore) PTE Ltd., The Assistant Vs.

C/o CA (India) Technologies Commissioner of India Private Limited, Income Tax, S1 Wipro SEZ, International Taxation, Doddathogur Village, Circle2 (1)(1), Begur Hobli, Mumbai.

Electronic City, Bangalore-560100.

[PAN :AAHCC8349Q]

(Appellant) .. (Respondent Appellant by : Shri Ajit Jain, with Shri, Siddesh Chaugule, ARs Respondent by: Shri Krishna Kumar, Sr. DR Date of Hearing 17.09.2025 Date of Pronouncement 16.12.2025

O R D E R

PER SUCHITRA KAMBLE, JUDICIAL MEMBER:

This appeal is filed by the Assessee against the appellate order dated 31.03.2024 passed by the Assistant Commissioner of Income Tax(International Taxation) Mumbai, relating to the Assessment Year

2022-23.

2. The assesse has raised the following grounds of appeal:

1. Final assessment order is bad in law and on facts

1.1 The Order passed by the Ld. AO u/s 143(3) r.w.s 144C(13) of the Act, is bad in law and on facts, as it is based on surmise and conjectures and is in gross violation of principles of natural justice

2. Erroneous