Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified
Section 144C(1) of the Act. 9. The Assessee filed its objections to the draft assessment order before the Dispute Resolution Panel [DRP] which were rejected by an order dated 27.12.2023. During the proceedings before the DRP, the Assessee also furnished additional evidence including with regard to allocation of corporate charges and repair and maintenance services. However, the DRP upheld