Trio Inc., a company incorporated in Country T, is engaged in manufacturing of computer hardware parts. It also owns an online social networking…

Trio Inc., a company incorporated in Country T, is engaged in manufacturing of computer hardware parts. It also owns an online social networking site, Attire. Nice Ltd., an Indian Company, imports computer hardware parts from Trio Inc. During the previous year 2023-24, Nice Ltd. did not import any computer hardware parts from Trio Inc. but paid - 5,50,000 on 24 th July, 2023 to Trio Inc. for advertising its business on the platform of Attire. However, Nice Ltd. neither deducted tax at source nor equalisation levy on such payment. On 1-4-2023, Nice Ltd. advanced a loan of 2.5 crores to Xylo Inc., an Australian company. As on the date of loan, the book value of total assets in the books of Xylo Inc. was - 4.52 crores. Out of the ten directors of Xylo Inc., five are appointed by Nice Ltd. Xylo Inc. repaid the entire loan along with interest thereon on 31 st March, 2024. On 9.11.2023, Trio Inc. sold 3,500 equity shares held by it in an Indian Company, XYZ Ltd. for 102 per share. These shares were bought by Trio Inc. on 15 th April, 2011 for 36.40 per share. Both the purchase and sale of shares were effected through a recognized stock exchange in India and STT is paid on purchase and sale. Fair Market Value of these shares on 31-01-2018 was 90 per share. CII for F.Y.2011-12 – 182; F.Y.2023-24 – 348. Nice Ltd. received the draft order from the Assessing Officer as per section 144C of the Income-tax Act, 1961 due to variations determined by the Transfer Pricing Officer in the arm's length price for the A.Y. 2023-24. However, Nice Ltd. does not prefer to file the objection against the draft order before the Dispute Resolution Panel; Instead, it wants to file an appeal before the CIT (Appeals) under section 246A against the final order received from the Assessing Officer. From the information given above, choose the most appropriate answer of MCQs 1 to 4: