आदेश/ORDER

PER S. R. RAGHUNATHA, AM:

The present appeal filed by the Revenue is directed against the order dated 17.10.2025 passed by the Learned Commissioner of Income Tax (Appeals)-19, Chennai [hereinafter referred to as “Ld.CIT(A)”], arising from the assessment order dated 30.03.2024 passed by the Deputy Commissioner of Income Tax, Central Circle-2, Madurai [hereinafter referred to as “the AO”] u/s.153A r.w.s 263 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment Year 2018-19.

2. The Revenue has raised the following grounds of appeal:

1. The order of the learned Commissioner of Income Tax (Appeals) is erroneous on facts and in law.

2. The Ld.CIT(A) erred in giving relief to the assessee as the TPO made an upward adjustment of Rs.39,21,15,575/- to the value of inter-unit transfers and directed re-computation of the deduction u/s.10AA vide order u/s.92CA(3), instead of annulling the assessment order, the Ld.CIT(A) ought to have set aside the order directing the AO to make a fresh assessment after issue of draft order u/s.144C(1) to the assessee proposing the adjustments to be made.

3. The Ld.CIT(A) erred in deletion of the addition made without taking