“directions of the DRP”

Assessment ProceduresSection 144CSection 144C1,202 judgments

The decision most relied on for directions of the DRP is Commissioner of Income Tax v. Roca Bathroom Products (P) ltd. (445 ITR 537), cited in 269 judgments on BharatTax.

Leading authorities on directions of the DRP

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.

445 ITR 537 · 2022 · High Court

269

citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

Vijay Television (P.) Ltd. v. DRP

369 ITR 113 · 2014 · High Court

140

citing judgments

Passing a final assessment order under Section 143(3) directly, without first issuing a draft assessment order under Section 144C(1) for an eligible assessee, constitutes a fundamental jurisdictional defect. This defect cannot be cured by a subsequent corrigendum, especially if issued beyond the prescribed period of limitation.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India

388 ITR 383 · 2016 · High Court

citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

Capital IQ Information Systems India Pvt. Ltd. v. DCIT

32 Taxmann.com 21 · 2013 · ITAT

citing judgments

A change in depreciation policy impacts an entity's profitability, which is a key factor in assessing its suitability as a comparable company for transfer pricing analysis.

Shelf Drilling Ron Tappmeyer Ltd. v. ACIT (International Taxation)

457 ITR 161 · 2023 · High Court

citing judgments

The limitation period for passing an assessment order under Section 153 of the Income Tax Act prevails over the specific time restriction for passing a final order under Section 144C(13).

Software Paradigms Infotech (P.) Ltd. v. ACIT

89 Taxmann.com 339 · 2018 · ITAT

citing judgments

An assessment order passed without giving effect to the binding directions of the Dispute Resolution Panel (DRP) under section 144C(10) within the stipulated time under section 144C(13) is null and void and must be set aside.

Bombay and Delhi High Courts in Vodafone Idea Limited v. Central Processing Centre

459 ITR 413 · 2023 · High Court

citing judgments

When determining the date of receipt of Directions from the Dispute Resolution Panel (DRP) by the Assessing Officer (AO) for the purpose of limitation, the date of uploading the DRP's directions is considered the date of receipt, even if the AO claims to have received it later through email. This interpretation prevents parties from exploiting a later date to their advantage and adheres to a singular, unambiguous approach to reckoning limitation.

Trib.). 14. Bramhacorp Hotels & Resorts Ltd. v. DDIT

103 Taxmann.com 344 · 2019 · ITAT

citing judgments

The Assessing Officer must comply with the directions of the Dispute Resolution Panel (DRP) when passing final assessment orders, and failure to do so may warrant setting aside the assessment with a direction for compliance.

Judgments citing directions of the DRP

Dell India Private Ltd., Bangalore vs. JCIT, Bangalore

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 562/BANG/2015[2010-11]Status: DisposedITAT Bangalore18 Aug 2022AY 2010-11

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 92C

Aggrieved, the Assessee filed its objections before the DRP. The DRP vide its directions dated 30.12.2014, granted partial relief. Pursuant to the directions of the DRP, the AO passed the final assessment order dated 29.01.2015 in which the aggregate TP adjustment was reworked to Rs. 14,51,54,329/-. Aggrieved ... Sundaram Business Services Limited” • Informed Technologies India Limited • Jeevan Scientific Technology Limited 22.5 The learned AO / learned TPO erred in not following the directions of the DRP and erred in not giving the relief for allowing working capital adjustment. 22.6 The learned AO / learned TPO / Hon'ble DRP erred

The Great Eastern Shipping Co., Mumbai vs. Addl.C.I.T. RG.5(3), Mumbai

In the result, appeal by assessee is partly allowed in the terms aforesaid

ITA 197/MUM/2013[2008-09]Status: DisposedITAT Mumbai11 Aug 2022AY 2008-09

For Appellant: Shri Percy j. Pardiwalla, Sr. Advocate with S/Sh. Jitendra Jain& Rashid PoonawalFor Respondent: Dr.Yogesh Kamat , CIT and Shri Sambit Mishra

Section 115JSection 143(3)Section 14ASection 14A(2)

tonnage income. (iv) Ground No.13: Disallowance of expenditure while computing Short Term Capital Gain. (v) Ground No.14: AO failed to comply with the directions of the DRP in not granting credit for TDS. TRANSFER PRICING ISSUES(T.P ISSUES): (i) Ground No.15 : General (ii) Ground No.16 to 18: T.P adjustment ... case of ACIT vs. Vireet Investments Pvt. Ltd. 58 ITR(T) 313(Del). 9. Per contra, the ld.Departmental Representative vehemently defended directions of the DRP and the assessment order qua disallowance made under section 14A r.w.r. 8D. 10. Both sides heard. The assessee has made suo motu disallowance of Rs.36

M/S. Onmobile Global Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 5(1)(2), Bengaluru

In the result, both these appeals are partly allowed

ITA 2560/BANG/2019[2015-16]Status: DisposedITAT Bangalore10 Aug 2022AY 2015-16

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 14ASection 234BSection 244ASection 32

DRP which vide its directions dated 28.09.2018, rejected the Assessee’s objections to a large extent while granting marginal relief. Pursuant to the directions of the DRP, the AO passed the final assessment order dated 28.11.2018 in which the TP adjustment was reduced

M/S Onmobile Global Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-5(1)(2), Bangalore

In the result, both these appeals are partly allowed

ITA 139/BANG/2019[2014-15]Status: DisposedITAT Bangalore10 Aug 2022AY 2014-15

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 14ASection 234BSection 244ASection 32

Yokogawa India Limited, Bangalore vs. Assistant Commissioner of Income Tax, Ltu, Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 588/BANG/2020[2008-09]Status: DisposedITAT Bangalore08 Aug 2022AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahu

For Appellant: Sri Padam Chand Khincha, A.RFor Respondent: Shri Pradeep Kumar, D.R

Section 234BSection 40A(2)

Marketing Activity Fees instead of considering the ALP at NIL. Therefore in principle we do not find any error or illegality in the directions of the DRP however having regard to the peculiar facts and circumstances of the case wherein the assessee is having multiple and diversified international transactions involving

Cae Flight Training (India) Private Limited, Bengaluru vs. The Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 520/BANG/2022[2016-17]Status: DisposedITAT Bangalore02 Aug 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 520/Bang/2022 Assessment Year : 2016-17 M/S. Cae Flight Training (India) Pvt. Ltd., Survey No. 26 & 27, The Deputy Bandaramanahalli Commissioner Of Village, Income Tax, Anneshwara Panchayat, Central Circle – 2 (2), Kasaba Hobli, Vs. Bangalore. Devanahalli Taluk, Bengaluru – 562 110. Pan: Aadcc1248A Appellant Respondent Assessee By : Shri Ketan Ved, Ca : Shri Sumer Singh Meena, Revenue By Cit Dr-1 Date Of Hearing : 02-08-2022 Date Of Pronouncement : 02-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 12/04/2022 By The Ld.Dcit, Central Circle – 2(2), Bangalore On Following Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case & In Law, M/S. Cae Flight Training (India) Private Limited (Hereinafter Referred To As The "Appellant") Respectfully Craves Leave To Prefer An Appeal Under Section 253 Of The Income-Tax Act, 1961 ("The Act") Against The Order Passed By The Deputy Commissioner Of Income-Tax, Central Circle

For Appellant: Shri Ketan Ved, CA

Section 253Section 92CSection 92D

following grounds: That on the facts and in the circumstances of the case and in law and based on the directions of the DRP: 1. The Ld. AO erred in law and on facts, in assessing the total income at INR 9,50,76,864/- as against returned income

M/S. Lancesoft India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, the appeal filed by the assessee stands allowed for statistical purposes

ITA 273/BANG/2021[2016-17]Status: DisposedITAT Bangalore02 Aug 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 273/Bang/2021 Assessment Year : 2016-17 M/S. Lancesoft India Pvt. Ltd., The Deputy 7/1, Manohar Plaza, Commissioner Of Kundalhalli Gate, Income Tax, Brookfields, Itpl Circle – 4(1)(1), Road, Vs. Bangalore. Bangalore – 560 066. Pan: Aaacl9790K Appellant Respondent : Shri K.R. Vasudevan & Assessee By Smt. R. Rashmi, Advocates : Shri Sumer Singh Meena, Revenue By Cit Dr-1 Date Of Hearing : 02-08-2022 Date Of Pronouncement : 02-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Assessment Dated 30/04/2021 Passed By The National E-Assessment Centre, Delhi U/S. 143(3) R.W.S 144C(13) R.W.S. 144B Of The Act On Following Concise Grounds Of Appeal: “The Grounds Mentioned Hereinafter Are Without Prejudice To Each Other Wrong Characterization 1. The Learned Tpo Erred In Characterizing The Services Rendered By The Appellant Erroneously As Ites Whereas The Appellant Renders Staff Recruitment Services, Which Has Vitiated The Comparability Analysis;

For Respondent: Shri K.R. Vasudevan &

Section 133(6)Section 143(3)Section 92C

appellant Wrong computation of Margin 8. The Learned TPO has committed mistakes in computation of margin and has failed to follow the directions of the DRP in this regard; Working Capital adjustment 9. The Learned TPO/ DRP erred in not allowing the working capital adjustment, at actuals, as upheld

M/S. Meritor C vs. India Private Limited, Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 249/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Jul 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri C. Ramesh, A.RFor Respondent: Shri Praveen Karanth, D.R

Section 133(6)Section 143(3)Section 92C

without any verification and rejecting the comparable, thereby the order of the TPO is bad in law and not as per the directions of the DRP. xi) not appreciating the fact that, the DRP has not considered specific objections in regard to the issues such as functionality, diversified activity, presence ... basis of the order of the Transfer Pricing Officer U/s.92CA(3) of the Act, in the order dated 24.03.2021 giving effect to the directions of the DRP in the order dated 16.02.2021, towards the interest receivable on alleged delay in recovery of receivables ignoring the fact that, there

M/S. Bosch Limited, Bangalore vs. Commissioner of Income Tax, Ltu, Bengaluru

In the result, the appeal by the assessee is allowed

ITA 475/BANG/2020[2014-15]Status: DisposedITAT Bangalore29 Jul 2022AY 2014-15

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Percy Pardiwala, Sr. CounselFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 263Section 32ASection 35

along with certain additions in the corporate tax front against which the assessee filed its objections before the DRP. In pursuance of the directions of the DRP, the AO passed the final assessment order u/s. 143(3) r.w.s. 144C of the Act dated 14.2.2018. 3. The CIT issued a show

M/S. Blue Coat Network (India) Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 1(1)(2), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 2623/BANG/2019[2015-16]Status: DisposedITAT Bangalore29 Jul 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2623/Bang/2019 Assessment Year : 2015-16 M/S. Blue Coat Network (India) Pvt. Ltd., Unit No. 1001 & 1002, The Deputy 10Th Floor, Rmz Campus Commissioner Of 8-B, Income Tax, Plot No. C-L, Sarjapur Circle – 1(1)(2), Marathalli Outer Ring Bangalore. Vs. Road, Bangalore – 560 037. Pan: Aahcs7844Q Appellant Respondent Assessee By : Shri Chavali Narayan, Ca : Dr. Manjunath Karkihalli, Revenue By Cit Dr Date Of Hearing : 14-06-2022 Date Of Pronouncement : 29-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 22/10/2019 Passed By Ld.Dcit, Circle -1 (1)(2), Bangalore For A.Y. 2015-16 On Following Grounds Of Appeal:

For Appellant: Shri Chavali Narayan, CA

Section 143(2)

2623/Bang/2019 support service segment and Data center service segment on the basis of revenue by the Ld.TPO. It is submitted that the directions of the DRP has not been followed by the Ld.TPO while passing the impugned order. Further, the Ld.AR submitted that, in Ground no. 4, the directions ... computation of PLI. Accordingly, the PLI may be recomputed, if need be. This objection is accordingly disposed.” 13.5 We note that the directions of the DRP has not been followed by the Ld.TPO. The Ld.TPO is directed to pass the order in consonance with the directions of the DRP

Airlinq Technology Private Limited (Formerly Known As Globetouch Technologies Private Limited), Bengaluru vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 231/BANG/2021[2016-17]Status: DisposedITAT Bangalore28 Jul 2022AY 2016-17

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.231/Bang/2021 : Asst.Year 2016-2017 M/S.Airlinq Technology Pvt. Ltd. The Deputy Commissioner Of (Formerly Known As Globe Touch Income-Tax, Circle 3(1)(1) V. Bangalore. Technologies Private Limited) 306, 100 Feet Road, Binna Mangala Stage – 1, Indiranagar Bangalore – 560 038. Pan : Aafcg7626L. (Appellant) (Respondent) Appellant By : S/Sri.Ajit Kumar Jain & Siddesh Chaugule, Cas Respondent By : Dr.Manjunath Karkihalli, Cit-Dr Date Of Pronouncement : 28.07.2022 Date Of Hearing : 21.07.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 29.03.2021 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2016-2017. 3. The Brief Facts Of The Case Are As Follows: The Assessee Was Incorporated On 15.10.2014 As A Wholly Owned Subsidiary Of Globetouch Inc, Usa. The Assessee Is Engaged In The Business Of Rendering Software Development Services (Swd) To Globetouch Inc. For The Assessment Year 2016-2017, The Return Of Income Was Filed Declaring An Income Of Rs.4,23,01,510 Under The Normal Provisions Of The Income-Tax Act. The Assessment Was Selected

For Appellant: S/Sri.Ajit Kumar Jain & Siddesh Chaugule, CAsFor Respondent: Dr.Manjunath Karkihalli, CIT-DR

Section 143(2)Section 143(3)Section 92CSection 92D

above ground deals with correction of margin. The learned AR has submitted that the AO has erred in giving effect to the directions of the DRP wherein the ALP Net Cost Plus markup has been considered as 27.66% as against 25.60%. The learned AR has also sought consideration of correct

M/S Quicklogic Software (India) Pvt. Ltd., Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bengaluru

In the result, the appeal filed by the assessee stands partly allowed

ITA 181/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Jul 2022AY 2017-18

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 181/Bang/2022 Assessment Year : 2017-18 M/S. Quicklogic Software (India) Pvt. Ltd., No. 10 Brindavan, The Deputy 3Rd Floor, Commissioner Of Yashoda Nagar Main Income Tax, Road, Circle 3(1)(1), Jakkur Plantation, Vs. Bangalore. Bengaluru – 560 064. Pan: Aaacq0656P Appellant Respondent Assessee By : Shri Mahaveer C Jain, Ca : Shri Sumer Singh Meena Cit Revenue By Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 27-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 25/01/2022 By The National Faceless Assessment Centre For A.Y. 2017-18 On Following Revised Grounds Of Appeal:

For Appellant: Shri Mahaveer C Jain, CA

Section 142(1)Section 143(2)Section 92C

Ld.TPO computed interest on outstanding receivables at the rate equal to 5.975% on receivables that exceeded 90 days as per the directions of the DRP. It has been argued by Ld.AR that authorities below disregarded Page 30 IT(TP)A No. 181/Bang/2022 business/commercial arrangement between the assessee

Cerner Healthcare Solutions India Private Limited (Erstwhile Cerner Healthcare Solution Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 171/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Jul 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri Srinivas T. Bidari, CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(3)Section 154Section 270ASection 37Section 40

adjustment. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO pursuant to the directions of the DRP. The learned AR submitted before us that all the issues contended in this appeal are covered by the decision of the coordinate bench

Altimetrik India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 477/BANG/2021[2016-17]Status: DisposedITAT Bangalore27 Jul 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Smt. Rashmi R., AdvocateFor Respondent: Shri Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)

Bang) wherein it was held that the working capital adjustment should be allowed as per actuals. 18. The ld. DR supported the directions of the DRP. 19. We have heard rival submissions and perused the material on record. In the view of the ruling in the case of M/s. Huawei

Vena Energy Patan Power Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 2(2), Bangalore

In the result, ITA No.254/Bang/2022 is partly allowed, while

ITA 255/BANG/2022[2017-18]Status: DisposedITAT Bangalore26 Jul 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Srinivas T. Bidari, CIT(DR)

Section 115JSection 143(3)Section 40

Against the draft assessment order, the assessee filed objections 4. before the DRP, which confirmed the TP adjustments. In pursuance of the directions of the DRP, the AO passed the final assessment order. Aggrieved, the assessee is in appeal before the Tribunal. IT(TP)A Nos.252 to 255/Bang/2021 Page

Vena Energy Kn Wind Power Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, ITA No.254/Bang/2022 is partly allowed, while

ITA 254/BANG/2022[2017-18]Status: DisposedITAT Bangalore26 Jul 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Srinivas T. Bidari, CIT(DR)

Section 115JSection 143(3)Section 40

Vena Energy Mh Wind Power Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, ITA No.254/Bang/2022 is partly allowed, while

ITA 253/BANG/2022[2017-18]Status: DisposedITAT Bangalore26 Jul 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Srinivas T. Bidari, CIT(DR)

Section 115JSection 143(3)Section 40

Vena Energy Fatanpur Power Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, ITA No.254/Bang/2022 is partly allowed, while

ITA 252/BANG/2022[2017-18]Status: DisposedITAT Bangalore26 Jul 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Srinivas T. Bidari, CIT(DR)

Section 115JSection 143(3)Section 40

M/S. Sulzer Tech India P. Ltd., Navi Mumbai vs. Addl./Jt./ Dy./ Asstt. CIT/ Income Tax Officer, Delhi

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 633/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Jul 2022AY 2016-17

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ravi Saeana a/wFor Respondent: Shri Tejinder Pal Singh

Section 143(3)Section 144C(13)Section 92CSection 92C(1)

lower profit as compared to other comparable companies. 1.2. Without prejudice, the Ld. TPO/ AO erred in not giving effect to the directions of the DRP and in not revising the computation of adjustment to the income earned by the assessee on account of providing engineering, tendering, and IT support

M/S Ingersoll-Rand Climate Solutions Private Limited, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

In the result, the appeal of the assessees is partly allowed

ITA 729/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 Jul 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S

For Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)

segment). The DRP provided relief to the assessee and directed the deletion of addition made on account of interest attributable to inventory. The directions of the DRP enhanced the TP adjustment to Rs. 8,32,57,562. Consequently the AO passed the final assessment order. Aggrieved, the assessee ... provided in the DRP proceedings, which are extension of the TP proceedings and assessee cannot have any grievance on this count. The directions of the DRP resulted in enhancement of the TP adjustment to Rs. 7,87,45,717. 10. Before us, the ld. AR reiterated that