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Spectro Analytical Labs Private Limited Vs. AU, Income Tax Department

Case No: ITA No.5848/Del/2024
Court: Income Tax Appellate Tribunal, Delhi Bench
Date: 1/28/2026

Parties Involved

appellantSpectro Analytical Labs Private Limited
respondentAU, Income Tax Department

Facts Summary

The assessee, Spectro Analytical Labs Private Limited, is engaged in the business of material testing, inspection, and certification services. During the assessment year 2021-22, the assessee entered into several international transactions with its Associated Enterprises (AEs). The Transfer Pricing Officer (TPO) proposed a cumulative upward adjustment to the arm's length price of these transactions, resulting in an increase in the assessee's returned income. The assessee filed objections before the Designated Reviewing Panel (DRP), which issued directions on 30.09.2024. The final assessment order dated 28.10.2024 was passed without incorporating the DRP's directions, leading to the current appeal.

Decision in favour of

Assessee

Legal Issues

  • 1. Validity of the final assessment order passed without incorporating the DRP's directions.
  • 2. Whether the failure to incorporate DRP's directions renders the assessment order invalid.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

10 precedents cited in this judgement.

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