IN THE INCOME TAX APPELLATE TRIBUNAL, ‘I’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER &

SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER (Assessment Year :2023-24 GS Strategic Investments Vs. Assistant Commissioner of Limited Income Tax, International C/o. Sehajpreet Kaur Tax Circle- 2(3)(2), BBSR & Associates Mumbai

14^th Floor, Central Wing Tower 4, Nesco Centre Western Express Highway Goregaon (E)

Mumbai – 400 063 PAN/GIR No.AAFFC0912J (Appellant) .. (Respondent Assessee by Shri Ajit Jain Revenue by Shri Krishna Kumar, Sr. DR Date of Hearing 25/11/2025 Date of Pronouncement 30/12/2025 / O R D E R आदेश PER AMIT SHUKLA (J.M):

This appeal by the assessee is directed against the final assessment order dated 14 July 2025 passed by the Assessing Officer under section 143(3) read with section 144C(13) of the Income-tax Act, 1961, in pursuance of the directions issued by the Ld. Dispute Resolution Panel-1, Mumbai, dated 27 June 2025 for the assessment year 2023-

24.

2. At the threshold, we deem it appropriate to crystallise, with precision, the controversy which travels to us in the present appeal, for the dispute is not one of arithmetical computation but of the legal architecture governing