Transfer Pricing Officer-1, Kochi, made the order under Section 92CA(3) ITA No.44/2017 -3- of the Act. The Assessing Officer through Annexure-B draft assessment order dated 28.03.2014 proposed to finalize the income tax return of the assessee assessed total income as Rs.481,78,02,530/-. The assessee raised objections to the draft assessment order dated 28.03.2014. The issues