IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, D: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No. 3700/Del/2023 [Assessment Year: 2021-22]

GE Engine Services LLC, USA ACIT C/o 1^st Floor, Building- 7A, Circle Int Tax 1(3)(1), Standard Chartered Building, DLF Vs Civic Centre Cyber City, Phase III, Gurugram- Minto Road

122002 New Delhi- 110 002 Haryana PAN- AADCG1809R Assessee Revenue Assessee by Sh. Ravi Sharma, Adv.

M s. Shruti Khimta, AR Revenue by Sh. M.S. Nethrapal, CIT (DR) Date of Hearing 12.12.2025 Date of Pronouncement 11.03.2026

ORDER

PER BRAJESH KUMAR SINGH, AM, This appeal filed by the assessee is directed against the Final Assessment Order (FAO) passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 20.10.2023 pursuant to the directions of the Hon’ble Dispute Resolution Panel (DRP) vide order dated 13.09.2023 u/s

144C(5) of the Act for Assessment Years (AY.) 2021-22.

2. Ground no. 1 of the appeal and the submissions of the assessee are reproduced as under :

On the facts and circumstances of the case & in law, the assessment order passed by the Ld. AO under section