IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil Kumar, Judicial Member ITA No: 577/Ahd/2025 Assessment Year: 2022-23 Shell International B.V., Assistant C/o. Shell India Markets Commissioner of Pvt. Ltd., Vs Income Tax, Trent House, 1st Floor, Circle (International G. Block Plot No. C-60, Taxation)-1, Bandra Kurla Complex Ahmedabad Bandra East, Mumbai Maharashtra 400051 PAN: AAHCS9360D (Appellant) (Respondent)

Assessee Represented: Shri Tushar Hemani,Sr. Adv. &

Shri Parimalsinh B. Parmar, A.R.

Revenue Represented: Shri Sher Singh, CIT-DR Date of hearing : 17-03-2026 Date of pronouncement : 22-04-2026 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

This appeal is filed by the Assessee as against the final assessment order dated 04-01-2025 passed under section 143[3] rws 144C[13] of the Income Tax Act, 1961 [hereinafter referred as ‘the Act’] by the Assistant Commissioner of Income Tax relating to the Assessment Year 2022-23.

2. The Grounds of Appeal raised by the assessee reads as under:

“Shell International B.V. (herein referred to as the 'Appellant') craves leave to prefer appeal against the order passed by the