ACIT Circle 4(3) (2) Aaykar Bhavan, M. K. Road, Mumbai400 020. ..... Respondent Appellant by : Shri Satyaprakash Singh, Ld. AR Respondent by : Shri K. C. Selvamani, Ld. DR Date of hearing : 19/08/2024 Date of pronouncement : 24/09/2024 ORDER PER GAGAN GOYAL, A.M: This appeal by assessee is directed against the order of Ld. CIT (DRP2), Mumbai dated 25.02.2022passed u/s. 144C (5) and the AO's order passed u/s. 143(3) r.w.s. 144C (13) of the Income Tax Act vide dated: 29.03.2022(in short 'the Act') for A.Y. 201718. The assessee has raised the following grounds of appeal: 2 ITA No. 745/Mum/2022 Siddhayu Aayurvedic Research Foundation Pvt. Ltd. Based on the facts and circumstances of the case, Siddhayu Aayurvedic Research Foundation Pvt Ltd, (hereinafter referred to as the 'Appellant') respectfully craves leave to prefer an appeal against the order dated 29 March 2022 passed by Additional/ Joint/Deputy/ Assistant Commissioner of Income Tax/ Incometax Officer, National Faceless Assessment Centre, Delhi ('AO') in pursuance of the directions issued by Dispute Resolution Panel I ('DRP'), Mumbai on the following grounds: On the facts and in the circumstances of the case and in law, the learned AO, based on directions of DRP has: General 1. erred in assessing total income of the Appellant at INR 11,35,61,343/ as against returned income of INR 2,37,09,958/; Disallowance of write off of loan of INR 8, 91, 78,685/ advanced to stepdown subsidiary in Indonesia 2. Erred in holding that write off of loan advanced to stepdown subsidiary in Indonesia is not allowable as revenue expenditure on the ground that the loan is not given for Appellant's business purpose; 3. Erred in holding that the write off of such loan advanced to stepdown subsidiary in Indonesia is not an allowable loss even as per section 28 of the Incometax Act, 1961; 4 should have appreciated that such loss was incurred purely from commercial reason, which was in overall business interest of the Appellant and therefore, allowable expense under section 37(1) or allowable business loss under section 28 of the Act; Transfer pricing adjustment of INR 6, 72,600/ on account of corporate guarantee charges 5.Erred in making transfer pricing adjustment @ 0.5% on account of alleged corporate guarantee provided without appreciating that there was no corporate guarantee which was provided by Appellant to its AE; 6. without prejudice to above, erred in making transfer pricing adjustment on account of alleged corporate guarantee, without giving credit of charges recovered from its AE, wherein such credit was given in original TP order but not given in final order post Hon'ble DRP directions (without any such directions from Hon'ble DRP);without prejudice to above, erred in making transfer pricing adjustment on account of alleged corporate guarantee for 3 ITA No. 745/Mum/2022 Siddhayu Aayurvedic Research Foundation Pvt. Ltd. the entire year, without appreciating that such guarantee was provided only for part of the year; Levy of interest under section 234B of the Act 8. Erred in levying interest of INR 1, 28, 26, 58,684/ under section 234B of the Act: Initiation of penalty proceedings under section 270A of the Act 9. erred in initiating penalty proceedings under section 270A of the Act; Initiation of penalty proceedings under section 271AA of the Act 10. Erred in initiating penalty on account of nonreporting of investment in Form 3CEB under section 271AA of the Act. The above grounds of appeal are mutually exclusive and without prejudice to one another. The A