“final assessment order”

SWIFT IMPEX PRIVATE LIMITED, NEW DELHI,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-27, NEW DELHI, NEW DELHI

document.\n\n26 FEB 2024\nCasseisséde\nIncome 1883\nACVT IHANDEWALA EXT. NEW DELHI NEW DELHI Delhi, 110055\n\n3.\nCopies of the final assessment orders should be forwarded to this office immediately after\npassing the orders. Proposal for retention of seized material should also be forwarded to this office\nwithin

SWIFT IMPEX PRIVATE LIMITED, NEW DELHI,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-27, NEW DELHI, NEW DELHI

In the result, all the six appeals of the assessee are allowed

digital signature may be taken as date of document.\nACVT JHANDEWALAN EXT. NEW DELHI NEW DELHI Delhi, 110055\n3.\nCopies of the final assessment orders should be forwarded to this office immediately after\npassing the orders. Proposal for retention of seized material should also be forwarded to this office\nwithin

SWIFT IMPEX PRIVATE LIMITED, NEW DELHI,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-27, NEW DELHI, NEW DELHI

In the result, all the six appeals of the assessee are allowed

digital signature may be taken as date of document.\nACVT IHANDEWALA EXT. NEW DELHI NEW DELHI Delhi, 110055\n\n3. Copies of the final assessment orders should be forwarded to this office immediately after\npassing the orders. Proposal for retention of seized material should also be forwarded to this office

TREND MICRO AUSTRALIA PROPRIETARY LIMITED,AUSTRALIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE INT. TAX 3(1)(1), DELHI

In the result, assessment order is quashed and appeal of the assessee is allowed

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं. 2730/धिल्ली/2023 (नि.व. 2020-21) Trend Micro Australia Proprietary Ltd., Level-15, 1-Pacific Highway North, Sydney Nsw 2060, Australia 2060 ...... अपीलार्थी/Appellant Pan: Aaect-4864-E बिाम Vs. Deputy Commissioner Of Income Tax, International Taxation, Circle 3(1)(1), Civic Centre, .....प्रनिवादी/Respondent New Delhi 110002 अपीलार्थी द्वारा/ Appellant By: Shri Vishal Kalra, Advocate, Ms. Reema Grewal, Chartered Accountant & Ms. Snigdha Gautam, Advocate प्रनिवादीद्वारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुिवाई की निथर्थ/ Date Of Hearing : 22/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 20/03/2026 आदेश/Order Per Vikas Awasthy, Jm:

hereinafter referred to as ‘the Act’), for AY 2020-21. 2. The solitary issue assailed by the assessee in appeal is validity of final assessment order dated 30.07.2023, on the ground of limitation. 2 3. Shri Vishal Kalra, appearing on behalf of the assessee submits that pursuant to directions ... Dispute Resolution Panel (DRP) dated 30.05.2023, the Assessing Officer (AO) was duty bound to passed final assessment order within one month from the end of the month in which DRP directions were communicated to the AO. In the present case, the DRP directions were communicated

MALL HOTEL LIMITED,DELHI vs. DCIT , DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

order placed in the paper book Page No. 85 to 88, the similar issue has been considered by the A.O. but in the final Assessment Order for the Assessment Year 2018-19 placed on paper book 89 to 90 no such disallowance has been made. Considering the above facts

MALL HOTEL LIMITED,DELHI vs. DCIT , DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

order placed in the paper book Page No. 85 to 88, the similar issue has been considered by the A.O. but in the final Assessment Order for the Assessment Year 2018-19 placed on paper book 89 to 90 no such disallowance has been made. Considering the above facts

MALL HOTEL LIMITED,DELHI vs. DCIT , DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

order placed in the paper book Page No. 85 to 88, the similar issue has been considered by the A.O. but in the final Assessment Order for the Assessment Year 2018-19 placed on paper book 89 to 90 no such disallowance has been made. Considering the above facts

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

That the PCIT erred in setting aside the assessment order on aforesaid issues, without even appellant, thereby, not demonstrating how and why the final assessment order was erroneous and prejudicial to the interests of the Revenue, qua such issues.\nQua huge claim of advertisement expenses\n13. That on the facts ... issue, without even recording any prima facie findings on merits despite detailed submission furnished by appellant, thereby, not demonstrating how and why the final assessment order was erroneous and prejudicial to the interests of the Revenue, qua such issue.\nThe appellant craves to leave, to add, to alter, to amend

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

In the result, the appeal filed by the assessee is allowed in above terms

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Hearing 10/02/2026 Date of Pronouncement 18/03/2026 ORDER PER S. RIFAUR RAHMAN, AM This appeal has been filed by the assessee against the final assessment order dated 24.10.2024 passed u/s 143(3) r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions ... respect of international transactions and specified domestic transactions. Several transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated by the appellant before us in the following grounds of appeal. “1. That the National Faceless Assessment Centre ("NaFAC")/Ld. Assessing Officer

HOME CREDIT INTERNATIONAL A.S.,CZECH REPUBLIC vs. ASSISTANTDEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, GURGAON HARYANA

In the result, the appeal of the assessee is allowed

Bench: Shri Vikas Awasthy, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

against income of Rs. 85,41,58,381/- returned by the Appellant. 2. That on the facts and circumstances of the case, the Final Assessment Order dated 27.10.2023 ("Impugned Order") passed under Section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 ('Act') is barred by limitation having ... /2023-24/1056206360(1) is also not being authenticated on the income tax website and hence, therefore the DRP directions are invalid. 6. That the final assessment order dated 27.10.2023 passed by the AO is illegal and void-ab-initio having not been passed in conformity with the directions issued

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Hearing 10/02/2026 Date of Pronouncement 18/03/2026 ORDER PER S. RIFAUR RAHMAN, AM This appeal has been filed by the assessee against the final assessment order dated 26.07.2022 passed u/s 143(3) r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions ... determination of ALP in respect of specified domestic transactions. Certain transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated by the appellant before us in the following concise grounds of appeal. “1. The Ld. AO has erred

NIDEC MOBILITY INDIA PRIVATE LIMITED,GURGAON, INDIA vs. COMMISSIONER OF INCOME-TAX (APPEAL), CENTRAL NER, GUWAHATI, GUWAHATI

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: SHRI RAMIT KOCHAR (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

92CA(3). The assessee submitted before the AO that it contemplate to file an appeal with ld. CIT(A) against final assessment order of the AO , instead of filing objections with ld. DRP. The ld. AO passed final assessment order dated 26.11.2021 u/s 143(3) r.w.s. 144C(3) r.w.s. 144B ... additions towards adjustment made towards ALP determination of Royalty payments as were proposed by TPO , and added by the AO in the final assessment order dated 26.11.2021, but the assessee also 4 challenged the additions as were made by CPC u/s 143(1) in this proceeding before

THE BANK OF TOKYO MITSUBISHI UFJ,NEW DELHI vs. DCIT, CIRCLE- 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed

said income Rs, 668,07,07,663/- was denied by the Assessing Officer.\nThe calculation of the taxable income in the final assessment order by the AO is\nreproduced as under.\n(Amount in INR)\n1. Income as declared in ITR before\ndeduction ... Pg.9) however, the DRP has not decided the\naforesaid issue in the order dated 18 September 2017.\n6. Accordingly, in the final assessment order, the AO reiterated the stand taken\nby him in the draft assessment order and computed deduction for head office\nexpenditure under section