EXCELACOM TECHNOLOGIES PRIVATE LIMITED,SIRUSERI, KANCHEEPURAM vs. ITO CORP WARD -2(1) CHENNAI, CHENNAI

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ITTPA 13/CHNY/2026Status: DisposedITAT Chennai06 May 2026AY 2022-202314 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the DRP's directions regarding the inclusion/exclusion of comparables were based on an incorrect understanding of the assessee's objections. Specifically, the DRP directed the exclusion of comparables that the assessee had not objected to, and failed to consider the assessee's specific objections to three comparables. The Tribunal noted that the TPO initially selected 18 comparables, reduced to 13, and the assessee's objections before the DRP were not clearly articulated or considered. Consequently, the Tribunal found that the issue of inclusion/exclusion of comparables needed to be examined afresh. Citing a coordinate bench decision in Xchanging Solutions Ltd. vs. DCIT, the Tribunal held that such matters, when remitted, can only be sent back to the AO. Therefore, the issue of inclusion/exclusion of comparables was remitted back to the AO with a direction to make a reference as appropriate for a fresh examination on merits. The legal grounds (2-6) were rendered academic. Ground 1 was general and Ground 16 was consequential. The Tribunal did not decide on the PLI computation methodology or the upward adjustment of revenue on merits, as these were intertwined with the comparables issue that was remitted.

What were the facts?

The assessee, Excelacom Technologies Pvt. Ltd., is in appeal against the final assessment order passed by the Assessing Officer (AO) under section 143(3) r.w.s 144C(13) of the Income Tax Act, 1961, for Assessment Year 2022-23. The assessee, engaged in providing telecom products solution, consulting services, and professional services, reported a loss. The AO referred the case to the Transfer Pricing Officer (TPO) who made a transfer pricing adjustment of Rs. 2,30,17,000. The Dispute Resolution Panel (DRP) directions resulted in an increased adjustment of Rs. 6,54,45,000, leading to the final assessment order. The assessee's transfer pricing study used the Transaction Net Margin Method (TNMM) and excluded depreciation and amortization expenses for Profit Level Indicator (PLI) computation. The TPO rejected this approach, reworking the margins by including depreciation.

What were the issues?

1. Whether the directions issued by the Dispute Resolution Panel (DRP) under section 144C(5) were bad in law and passed without complying with statutory requirements, and whether the DRP erred in issuing directions prejudicial to the appellant without providing an opportunity of being heard (Grounds 2, 3, 4)? The assessee argued that the DRP's directions were legally flawed, procedurally deficient, and violated principles of natural justice. The revenue did not record specific arguments on these points. 2. Whether the DRP and AO erred in rejecting the assessee's computation of PLI by excluding depreciation and amortization, and instead computed PLI considering operating margin after charging depreciation and amortization (Ground 7)? The assessee contended that depreciation on in-house developed software, which did not yield operating profit in the year under consideration, should be excluded. The revenue, through the TPO, argued that depreciation on software used in day-to-day operations is integral and should be considered. 3. Whether the DRP and AO erred in making an upward adjustment of Rs. 6,54,45,000 to the revenue and in rejecting the assessee's transfer pricing study, conducting an independent search with different selection criteria without proper basis, and not applying an upper turnover filter to select comparables (Grounds 10, 11, 12)? The assessee argued that the TPO's independent search and selection criteria were arbitrary and lacked basis, and that an upper turnover filter should have been applied. The revenue did not record specific arguments on these points. 4. Whether the DRP erred in its understanding of the assessee's objections regarding the inclusion/exclusion of comparables, leading to incorrect directions (Grounds 13, 14, 15)? The assessee contended that the DRP misunderstood the objections, leading to the exclusion of comparables not objected to by the assessee and failure to consider objections to specific comparables.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144C(5),Section 144C(3),Section 144B,Section 234B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY.S

Hearing: 30.04.2026Pronounced: 06.05.2026

आदेश / O R D E R

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the final order of the assessment passed by Assessment Unit (in short "AO") passed u/s. 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 (in short "the Act") dated 25.11.2025 for Assessment Year (AY) 2022-23. The assessee raised the following grounds of appeal: “1. For that the Directions of the Dispute Resolution Panel and consequently the order of the Assessing Officer is without jurisdiction, is contrary to law, facts and circumstances of the case and at any rate is opposed to the principles of equity. natural justice and fair play.

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 2 -: Legal Grounds 2. For that the directions issued by the Dispute Resolution Panel u/s. 144C(5) is bad in law.

3.

For that the directions issued by the Dispute Resolution Panel u/s 144C(5) was passed without complying with the statutory requirements of law.

4.

For that the Dispute Resolution Panel erred in issuing directions prejudicial to the interests of the appellant enhancing the total income of the appellant without providing the appellant an opportunity of being heard.

5.

For that the order of the Assessing Officer passed u/s.143(3) r.w.s.144C(3) r.w.s.1448 of the Income Tax Act dated 25.11.2025 is bad in law.

6.

For that the Assessing Officer completed the assessment vide order passed u/s.143(3) r.w.s. 144C(3) r.w.s. 144B of the Income Tax Act dated 25.11.2025 without complying with the statutory requirements of law.

PLI to be computed by using the operating margin before charging depreciation and amortization

7.

For that the Dispute Resolution Panel and consequently the Assessing Officer erred in rejecting the computation of PLI adopted by the appellant and computed the PLI of the appellant by considering the operating margin after charging depreciation and amortization.

8.

For that the Dispute Resolution Panel and consequently the Assessing Officer failed to appreciate that the full impact of software development on revenue would only be seen in the ensuing years.

9.

For that without prejudice to the above, at best, Dispute Resolution Panel and consequently the Assessing Officer ought to have computed PLI by eliminating the impact of depreciation to the extent pertaining to the in-house product developed by the appellant.

Upward adjustment of Revenue of Rs.6,54,45,000/-

10.

For that the Dispute Resolution Panel and consequently the Assessing Officer erred in making an upward adjustment of Rs.6,54,45,000/- to the revenue of the appellant.

11.

For that the Dispute Resolution Panel and consequently the Assessing Officer erred in affirming the action of the Transfer Pricing Officer in rejecting the transfer pricing study conducted by the

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 3 -: appellant and conducting an independent search using different selection criteria without proper basis. 12. For that the Dispute Resolution Panel and consequently the Assessing Officer erred in not applying an upper turnover filter to select comparables. 13. For that the Dispute Resolution Panel erred in stating that the appellant had objected to the selection of 18 comparables as being functionally dissimilar (though only 13 comparables were selected by the Transfer Pricing Officer). 14. For that the Dispute Resolution Panel failed to appreciate that the appellant had only objected to 3 out of the 13 comparables as being functionally dissimilar to the appellant namely IDS Infotech Ltd., Systango Technologies Ltd. and Sasken Technologies Ltd and these have not been appropriately appreciated by the Dispute Resolution Panel. 15. For that the Dispute Resolution Panel erred in concluding that the following comparables are functionally dissimilar to the appellant • Orchasp Limited • Great Software Laboratory Pvt. Ltd. • Gameshastra Solutions Pvt Ltd • Suntech Web Services Pvt Ltd. • Data Collection Infotech (India) Pvt. Ltd. Levy of interest u/s.234B 16. The appellant objects to the levy of interest u/s 234B of the Income Tax Act. For these grounds raised and such other grounds that may be raised, may be altered, amended or modified, with the leave of the Hon'ble Tribunal before or during the hearing of the appeal, it is most humbly prayed that the Hon'ble Tribunal may be pleased to: a) Quash the assessment order passed u/s. 143(3) r.w.s. 144C(3) r.w.s. 1448 of the Income Tax Act dated 25.11.2025 and/or b) Delete the upward adjustment of Rs.6,54,45,000/- to the revenue of the appellant and/or c) Pass such other orders as the Hon'ble Tribunal may deem fit.”

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 4 -: 2. The assessee is a subsidiary of Allfon LLC, who holds 50.03% of the paid up share capital in the assessee company. The assessee as per the transfer pricing study report (TPSR) is engaged in the business of providing telecom products solution, consulting services and professional services. The assessee filed a return of income for A.Y 2022-23 on 31.10.2022 declaring loss at Rs.40,59,834/- (being unabsorbed depreciation). The case was selected for scrutiny and the statutory notices were duly served on the assessee. The A.O made a reference to the TPO to determine the Arm’s Length Price (in short "ALP") of the international transaction the assessee has entered into with its associated enterprises. The TPO made a TP adjustment of Rs. 2,30,17,000/-. The A.O passed the draft assessment order incorporating the TP adjustment. Aggrieved, the assessee raised objections before the Disputes Resolution Panel (DRP). The directions of the DRP resulted in increased TP adjustment amounting to Rs.6,54,45,000. The A.O passed the final assessment order pursuant to the directions of the DRP against which the assessee is in appeal before the Tribunal.

3.

In the TPSR, the assessee chose itself as the tested party and as per the Form-3CED filed by the assessee following is international transaction entered into by the assessee during the year under consideration:

S.No. Nature of Transaction Name of the AE Amount (Rs.) MAM 1. Software development Allfon LLC, USA 35,57,32,486 TNMM services Total 35,57,32,486

4.

In the TPSR, the assessee has applied transaction net margin method (TNMM) as the most appropriate method (MAM) to determine the ALP and cash operating margins/cash operating cost i.e., the depreciation and amortization expenses were excluded for the purpose of profit level indicator

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 5 -: (PLI). The assessee chose 24 comparable companies the median of which was arrived at 12.92%. The assessee's PLI was computed at 14.83% and therefore the assessee in the TPSR concluded that the international transactions are at arm's length.

5.

The TPO also rejected the cash PLI computation of the assessee and reworked the margins of the assessee at 4.29%. The assessee raised objection stating that the revised PLI computation of the TPO has included depreciation as an operating expenses which is not correct. The assessee further submitted that the depreciation is treated as non-operating expense by the assessee since in-house developed software on which the depreciation is claimed has not yielded any operating profit to the assessee during the year under consideration. The assessee therefore submitted that depreciation should be excluded for the purpose of computing the PLI. The TPO however did not accept the submissions of the assessee for the reason that: • This approach adopted by the assessee is not acceptable for the reason that the said in house software 'Century Suite CRM' is an asset developed by the assessee in order to use it in the assessee's day to day operations and the said software has been used by the assessee in the year under consideration for the international transaction of provision of services as well. Hence the depreciation incurred on it is integral to the assessee's operations and is factor to be considered in pricing of the assessee's service • Moreover the depreciation claimed by the assessee as non- operating expense not only includes depreciation on in-house software but also includes depreciation on tangible assets such as buildings, computers, plant & machinery etc. which is not acceptable.

6.

The TPO rejected 21 of the comparables chosen by the assessee and conducted independent search for comparables. The TPO conducted fresh search and arrived at a final list of 13 comparables whose median was

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 6 -: 11.05%. Accordingly the TPO arrived at a TP margin of Rs.2,30,17,000/-. The final list of comparables chosen by the TPO and the computation of TP adjustment done by the TPO are extracted here under:

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 7 -: EXCLUSION OF DEPRECATION FROM OPERATING COST – Ground No. 7 to 9:

7.

We have heard the parties, and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee at the outset submitted that the impugned issue has been considered by the coordinate bench in assessee's own case for AY 2021-22 (IT(TP)A No.114/Chny/2024 dated 11.02.2026) where it has been held that: 14. We have heard the parties, and perused the material available on record. The assessee has developed in-house software and has accumulated towards the same from 2018. The assessee has deployed the software during the year under consideration and in the books of accounts claimed depreciation on the same. However for the purpose of computing the PLI, the assessee has treated the depreciation as non-operating i.e. cash margin is considered for the purpose of PLI. The argument of the assessee in this regard is that the use of software has not resulted in any impact in the revenue from operations being the first year of deployment. Accordingly the assessee is contending the depreciation is to be treated as extraordinary item to be excluded from the operating expenses for the purpose of benchmarking. On the other hand the contention of the revenue is that the very basis of claiming depreciation is that the asset is being put to use in the regular course of business and therefore excluding the same for PLI purpose is not correct. The revenue further contends that the Rule specifically provides that the depreciation is to be part of operating cost and therefore excluding depreciation would mean that the PLI computation is not as per the Rules. In this regard it is relevant to note here that the in-house software developed and deployed is customer relationship software and as per the submissions the purpose of the software is to improve the customer relationship which would ultimately result in increasing the revenue of the assessee. From the perusal of the records we notice that the overall depreciation claimed during the year Rs.3,15,17,330/- out of which Rs.2,48,61,255/- pertains to the software. During the course of hearing the ld AR drew our attention to the below table indicating the depreciation as percentage of profit before depreciation of the comparables to submit that the average depreciation percentage of comparables is 15.1% whereas the assessee's depreciation (including depreciation in software) is 83.39%. Accordingly it is argued that depreciation on software is skewing the results of bench marking and therefore should be treated as an extraordinary item for the year under consideration.

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 8 -:

15.

With regard to the issue of whether any extraordinary items could be adjusted for the purpose of determining the ALP under TNMM we will look at the relevant Rule 10B(1)(e) and Rule 10B(3) of the Rules which read as under

"Rule 10B - Determination of arm's length price under section 92C. (1)(a) to (d) *******

(e) transactional net margin method, by which,-

(i) the net profit margin realised by the enterprise from an international transaction or a specified domestic transaction entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by the enterprise or having regard to any other relevant base;

(ii) the net profit margin realised by the enterprise or by an unrelated enterprise from a comparable uncontrolled transaction or a number of such transactions is computed having regard to the same base;

(iii) the net profit margin referred to in sub-clause (ii) arising in comparable uncontrolled transactions is adjusted to take into account the differences, if any, between the international transaction or the specified domestic transaction and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of net profit margin in the open market;

(iv) the net profit margin realised by the enterprise and referred to in sub-clause (i) is established to be the same as the net profit margin referred to in sub-clause (iii);

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 9 -: (v) the net profit margin thus established is then taken into account to arrive at an arms length price in relation to the international transaction or the specified domestic transaction.”

(3) An uncontrolled transaction shall be comparable to an international transaction 96[or a specified domestic transaction] if— (i) none of the differences, if any, between the transactions being compared, or between the enterprises entering into such transactions are likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open market; or (ii) reasonably accurate adjustments can be made to eliminate the material effects of such differences. (emphasis supplied) 16 A combined perusal of the above rules makes it clear that for the purpose of comparison with uncontrolled transaction a reasonable accurate adjustment towards difference which could materially affect the net profit margin is permitted. Our attention was drawn to the following observations of the Hyderabad Bench of the Tribunal in the case of Qual Core Logic Ltd. v DCIT [2012] 22 taxmann.com 4 (Hyderabad) in this regard –

“57. We have heard both the parties on this and perused the material on record. In the present appeal, ALP of transactions carried was to be determined by comparing net profit of the taxpayer (tested party) with mean net profit of comparables. Only receipts and expenditure, having connection with international transactions, were required to be taken into account. Any receipt or expenditure having no bearing on price or margin of profit could not be taken into consideration. It is evident from statutory provisions that it is nowhere provided that deduction of depreciation is a must. Depreciation can be taken into account or disregarded in computing profit depending upon the context and purpose for which profit is to be computed. There is no formula which would be applicable universally and in all circumstances. "Net profit" used in Rule 10B can be taken to mean commercial profit. But depreciation in such profit on commercial principles has to be the "actual" amount by which the assets of business got depleted between the two dates separated by a year. It cannot be depreciation under tax or companies rules or as per policy of the company. In the case in hand, Revenue authorities went wrong in disregarding the context and purpose for which the "net profit" was to be computed. Depreciation, which can have varied basis and is allowed at different rates, is not such an expenditure which must be deducted in all situations. It has no direct connection or bearing on price, cost or profit margin of the international transactions. Object and purpose of the transfer pricing to compare like with the like, and to eliminate differences, if any, by suitable adjustment is to be seen. Therefore, there was justification on the part of the assessee in pleading that profits be taken without deduction of depreciation as depreciation was leading to large differences in margins for various reasons. Contention that depreciation would depend upon type of technology employed, age and nature of machinery used, is quite well-founded. Above, along with size of enterprise and investment in plant/machinery were important factors to be taken into account for comparison and for computing profit. There is considerable support for the contention raised on behalf of the assessee in the OECD Guidelines on Transfer Pricing. The claim of depreciation can lead to great difference in computing profits of comparables as depreciation is permitted depending upon nature of plant/machinery and year of use. Obviously there are

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 10 -: differences between the machinery employed by the taxpayer and other comparable concerns which is reflected in amount and percentage of depreciation claimed. How this variation and difference could be ignored under TP Regulations is neither shown nor explained. The assessee has debited high amount/ratio of depreciation. Other enterprises have claimed depreciation at much lower amounts. Size of the assets besides the age of the assets of comparables was leading to difference in the profit margins and in mean margin. On the contrary, claim of depreciation is eating up large chunk of profit in the case of the taxpayer. The CIT(A) has not said a word on "asset" employed and "risks" suffered by the tested party and the comparables. Thus, material differences needing suitable adjustment were ignored and a flawed analysis was carried even in appellate proceedings. Without considering obvious material differences, the contention of the assessee to take profit without depreciation was rejected. This rejection is not sound in law. This ground is allowed. Accordingly, we direct the Assessing Officer to recompute the ALP.”

17.

In assessee's case from the perusal of the table as extracted in the earlier part of this order it is factually established that the depreciation on software is materially affecting the profit margin of the assessee and it also establishes the fact that without the adjustment, the comparison with uncontrolled transaction will not be a proper bench marking exercise. It also substantiates the claim that the adjustment of depreciation is reasonably accurate considering that the depreciation as a percentage of profit before depreciation of the comparables is in the range of 15% and the assessee's after adjustment of the impugned depreciation is also in the range of 18%. The other reason as quoted by the assessee that the CRM software did not result in any benefit interms of the increase in revenue is also supported by the fact that the assessee has stopped making adjustment towards depreciation on software once the same stopped materially affecting the net margins from AY 2023-24. In view of these discussions and considering the facts unique to the present case, we are of the view that there is merit in the contention that the depreciation on software which is materially affecting the net margin needs to be adjusted for the purpose of bench marking. We direct the TPO to re-compute the PLI of the assessee accordingly.”

8.

From the perusal of the above findings of the Coordinate Bench, we notice that the adjustment towards depreciation is allowed for the reason that the assessee has factually established that the depreciation on software is materially affecting the profit margin of the assessee and that without the adjustment, the comparison with uncontrolled transaction will not be a proper bench marking exercise as per Rule 10B. For the year under consideration, the Ld AR drew our attention to the below workings to factually establish that depreciation on software is distorting the results of benchmarking where the

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 11 -: average depreciation percentage of comparables is 15.19% whereas the assessee's depreciation (including depreciation in software) is 65.08%:

9.

It is also relevant to consider the fact that the assessee has stopped making adjustment towards depreciation on software once the same stopped materially affecting the net margins from AY 2023-24. Considering the facts as elaborated herein above and the ratio laid down by the coordinate bench in assessee's own case (supra), we are of the view that the depreciation on software which is materially affecting the net margin for the year under consideration also needs to be adjusted for the purpose of bench marking and therefore direct the TPO to re-compute the PLI of the assessee accordingly.

INCLUSION/EXCLUSIONS FROM COMPARABLES – Ground No.10 to 15:

10.

The ld AR during the course of hearing submitted that the TPO's final list of comparables contained 13 comparables and the assessee before the DRP raised objections with regard to the independent search conducted by the TPO using fresh set of filters. The Ld. AR further submitted that the assessee before the DRP has objected to inclusion of 3 comparables viz., M/s. IDS

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 12 -: Infotech Ltd., M/s. Sysyango Technologies Ltd., and M/s. Sasken Technologies Ltd. (page 111 to 113 of paper book), which have not been properly considered by the DRP. The Ld. AR also submitted that the DRP has proceeded on an incorrect understanding that the assessee has objected to the 18 comparables (whereas the TPO has finally chosen only 13 comparables) chosen by the TPO and has proceeded to exclude 5 comparables which are not sought by the assessee. According, the Ld. AR prayed that the issue of exclusion of comparables need to be examined afresh since the DRP directions are not based on the objections raised by the assessee but based on incorrect understanding of facts.

11.

We heard the parties and perused the material on record. We notice that the TPO has initially chosen 18 comparables and after considering the submissions of the assessee the TPO arrived final list of 13 comparables (refer the list of comparables as extracted in the earlier part of this order). We further notice that the assessee while raising the objections before the DRP has mentioned the list of 18 comparables which were initially proposed by the TPO (refer Ground No.4 from page 14 & 15 of Form 35A) and generally objected to the independent search conducted by the TPO applying fresh filters. We also notice that the assessee during the course of DRP proceedings however sought exclusion of 3 comparables viz., M/s. I D S Infotech Ltd., M/s. Sysyango Technologies Ltd., and M/s.Sasken Technologies Ltd. (page 111 to 113 of paper book) and has submitted detailed written submissions in this regard. However, it is noticed that the DRP has proceeded to consider the 18 comparables as listed in the grounds raised by the assessee without considering the subsequent submissions, and has directed the TPO to exclude 5 comparables as listed below which were actually not contended by the assessee.

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 13 -: • Orchasp Limited • Great Software Laboratory Pvt. Ltd. • Gameshastra Solutions Pvt Ltd • Suntech Web Services Pvt Ltd. • Data Collection Infotech (India) Pvt. Ltd.

12.

We in this regard notice that the TPO in the order giving effect has excluded these 5 comparables from the final list of 13 comparables to arrive at revised list of 8 comparables that resulted in the enhancement of the TP adjustment to Rs.6,54,45,000/-. The assessee is now seeking the inclusion of the above 5 comparables and the exclusion of 3 comparables as was sought before the DRP. From the perusal of the facts as enumerated herein above, it is clear that the issue of inclusion/exclusion of comparables have been considered based on incorrect understanding of what is actually sought by the assessee to be included / excluded. Further, the DRP while adjudicating the objections have given directions to exclude comparables which are not objected to by the assessee and that the DRP has not considered the submissions made during the DRP proceedings seeking exclusion of 3 comparables. Therefore, we are of the considered view that the impugned issue needs to be considered afresh based on the correct understanding of objections raised by the assessee. We notice that the Bangalore Bench of the Tribunal in a recent decision in the case of Xchanging Solutions Ltd., vs. DCIT [(2026) 185 taxmann.com 337 (Bangalore Trib)] has held that even with regard to TP issues which is to be remitted back, the only authority to whom it can be sent back is the AO only. Therefore, we are remitting the above issue back to the AO with a direction to make a reference as appropriate so that the issue of inclusion/exclusion of comparisons as sought by the assessee is examined on merits afresh in accordance with law.

IT(TP)A No.13/Chny/2026 Excelacom Technologies Pvt. Ltd. :- 14 -: 13. Ground No.1 is general and ground No.16 is consequential. Hence these grounds do not warrant any separate adjudication. Considering our decision on merits, the legal grounds raised by the assessee in ground No.2 to 6 have become academic and left open accordingly.

14.

In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced on 06th day of May, 2026 at Chennai.

Sd/- Sd/- (एबी टी. वक�) (पदमावती यस) (ABY. T. Varkey) (Padmavathy.S) लेखा सद�य लेखा सद�य /Accountant Member लेखा लेखा सद�य सद�य �याियक �याियक सद�य �याियक �याियक सद�य सद�य / Judicial Member सद�य चे�नई/Chennai, �दनांक/Dated: 06th May, 2026. EDN, Sr. P.S आदेश क� �ितिल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF

Digitally signed by EJTADA DURGA EJTADA DURGA NARESH NARESH Date: 2026.05.13 10:27:49 +05'30'

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