IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘D’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER ITA No.2026/Del/2025 [Assessment Year: 2022-23]

Veritas Storage (Singapore) Ptd. Vs. Deputy Commissioner of Income Ltd. 9 Tamasek Boulevard, Tax, Circle-3(1)(1), Intl. Taxation, 39-01 Suntec Tower Two, Civic Centre, Minto Road, Singapore-038989 New Delhi-110002 PAN :AAFCV2394A (Assessee) (Revenue)

Assessee by Shri Tarun Gulati, Sr. Adv. &

Shri Nikhil Gupta, Adv. and Shri Prince Nagpal, Adv.

Revenue by Srhi M.S. Nethrapal, CIT-DR Date of Hearing 30.09.2025 Date of Pronouncement .12.2025

ORDER

PER KRINWANT SAHAY, AM:

Appeal in this case has been filed by the assessee against the order of the Assessing Officer dated 27.01.2025 for Assessment Year

2022-23 on following grounds of appeal Ground 1 - Violation of Principles of Natural Justice by the Ld. DRP

1.1 The Ld. Dispute Resolution Panel (DRP) has violated the principles of natural justice by failing to provide the Appellant with a pre-decisional hearing before raising a new issue. In the draft assessment order, the consideration from the sale of software was treated as Fees for Technical Serv