ORDER

PER MANISH AGARWAL, AM:

This appeal is filed by the Assessee against the final assessment order dated 17.05.2022 passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (‘the Act’ for short) by the DCIT, Central Circle-13(1), New Delhi for the Assessment Year 2018-19.

2. Brief facts of the case are that the assessee company was incorporated in December, 2006 as a subsidiary of Kronos Solutions Inc. and engaged in the business of providing software services/solutions and back office support services to its Associated Enterprises (“AEs”). The assess is 100% export-oriented unit and is on offshore development center for Kronos US. The return of income was filed on 30.11.2018 declaring total income at Rs.47,16,32,260/-. Since, the assessee is having international transactions with its AEs, therefore, a reference was made u/s 92CA(1) of the Act to the TPO. The TPO vide its order dated Nil has made adjustments to the international transactions with AEs wherein adjustment of Rs.10,79,15,788/- is made on the provisions of software development services and Rs.3,8253,681/- was made for provisions of ITeS segment. Accordingly, total enhancement of Rs.14,61,69,469/- is made by the TP