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"1. That the learned Assessment Unit, Income Tax Department ("AO") has erred both in law and on facts in determining total income of the appellant company at Rs. 17,93,00,500/- as against declared loss of Rs. 7,03,94,093/-in an order of assessment dated 29.10.2024 under section 143(3)/144C(13) read with section 144B of the Act.

2. That the learned AO/TPO/DRP has erred both in law and on facts in making an adjustment of Rs. 24,76,99,067/- to arms length price in respect of international transaction relating to import of goods for manufacturing of telecommunication equipment in an order dated 29.10.2024 read with order dated u/s of the 143(3)/144C(13) Act 30.10.2023/26.10.2024 u/s 92CA(3) of the Act and order dated 30.9.2024 u/s 144C(5) of the Act. 2.1 That the learned AO/TPO/DRP have also erred both in law and on facts in calculating the net margin of the appellant company and comparables, considering foreign exchange gain/loss related to revenue- earning operations as a non-operating item 2.2 That the learned AO/TPO/DRP has erred both in law and on facts in not accepting the valuation of goods so imported by the appellant company from related foreign supplier under section 14 of the Custom Act, 1962 read with Rule 2(2) of the Customs Valuation (Determination of value of imported goods) Rules vide SVB order no. F.N. SVB/CUS/103/2015 dated 17.6.2016.