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Relief

17. The Appellant prays that the appeal may be allowed, and the impugned final assessment order be set aside in the justice and equity."

3. The assessee at the time of hearing submitted that ground nos. 1 & 2 are general in nature, ground no.12 is not pressed and ground nos. 13 & 14 are consequential in nature or are premature. Thus, these grounds are dismissed. This leaves us to decide ground no 3 to 11 of the appeal.

4. Brief facts of the case show that assessee is engaged in delivering software-driven cloud networking solutions for large datacentre storage and computer environments. It also sells its products and services through distributor channel as well as directly to third party customers. It has receipts from India in the form of sale of standardized software, sale of software embedded in hardware, hardware replacement and IT(IT)A No.1159/Bang/2023 support services as well as training. Return of income was picked up for scrutiny.