This appeal is filed by the assessee against the order of The Additional Commissioner Of Income Tax, Special Range – 7, New Delhi (the ld AO) u/s 143(3)/ 92CA (3) and 144C (1) of The Income Tax Act (The Act) dated 30.08.2018 for AY 2014-15 determining total income of the assessee at Rs. 1416117999/- against the return of income filed by the assessee on 30.11.2014 at Rs. 113503990/-.

2. The only issue is the addition made by the ld AO on account of arm’s length price of the international transaction of Rs. 32614009/-. The assessee has raised the following grounds of appeal contesting the above transfer pricing adjustment:-

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