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“final assessment order”

Assessment ProceduresSection 144CSection 144C4,041 judgments

The decision most relied on for final assessment order is Parashuram Pottery Works Co. Ltd. v. ITO (106 ITR 1), cited in 486 judgments on BharatTax.

Leading authorities on final assessment order

Parashuram Pottery Works Co. Ltd. v. ITO
106 ITR 1 · 1977 · Supreme Court
486
citing judgments

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.
445 ITR 537 · 2022 · High Court
269
citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

CIT v. G.M. Knitting Industries (P.) Ltd.
376 ITR 456 · 2015 · Supreme Court
221
citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

Sultana Begum v. Prem Chand Jain
259 ITR 449 · 2003 · Supreme Court
147
citing judgments

Section 144C(4) uses a non-obstante clause to expedite the final assessment order, requiring the Assessing Officer to pass it immediately upon acceptance or lack of objection to the TPO's order, irrespective of broader time limits under Section 153.

Vijay Television (P.) Ltd. v. DRP
369 ITR 113 · 2014 · High Court
140
citing judgments

Passing a final assessment order under Section 143(3) directly, without first issuing a draft assessment order under Section 144C(1) for an eligible assessee, constitutes a fundamental jurisdictional defect. This defect cannot be cured by a subsequent corrigendum, especially if issued beyond the prescribed period of limitation.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India
388 ITR 383 · 2016 · High Court
71
citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

Travancore Diagnostics P. Ltd. v. ACIT
390 ITR 167 · 2017 · High Court
50
citing judgments

Failure to issue notice under section 143(2) before finalizing a reassessment order under section 147 is a fatal jurisdictional error, and this defect cannot be cured by invoking section 292BB of the Income-tax Act. Consequently, such a reassessment order is not sustainable in law.

Addl. CIT v. Mukur Corporation
111 ITR 312 · 1978 · High Court
49
citing judgments

When setting aside an assessment under Section 263(1) and directing a fresh assessment, the Commissioner need not record final conclusions or express final opinions on controversial points. It also interprets 'prejudicial to the interests of the Revenue' as meaning the assessment order is not in accordance with law, leading to the non-realization of lawful revenue.

Judgments citing final assessment order

Ncr Global Solutions Limited, Ireland vs. DCIT, Circle 2(2)(2) Int. Taxation, New Delhi

In the result, the appeal of the assessee is allowed

ITA 381/DEL/2023[2020-21]Status: DisposedITAT Delhi06 Oct 2026AY 2020-21

Bench: Shri Saktijit Dey, Hon’Ble & Dr. B. R. R. Kumar

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Vizay B.Vasanta, CIT-DR

Appellant") respectfully craves, leave to prefer an appeal under Section 253(1)(d) of the Income-tax Act, 1961 ("the Act") against final assessment order dated 9 June 2022 ("impugned order") (received by the Company on 10 June 2022) issued under Section 143(3) read with Section 144C

Schneider Electric It Business India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore

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

ITA 1585/BANG/2024[2020-21]Status: DisposedITAT Bangalore08 Jun 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Dr Divya K J, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 14ASection 80G

therefore it rejected the plea of the assessee that working capital adjustment would take into account the above adjustment. Accordingly in the final assessment order passed by the AO, the above condition was retained. 8. The only contention raised by the assessee is that if the working capital adjustment

Snf (India) Private Limited, Visakhapatnam vs. DCIT/ACIT, Circle - 3(1), Visakhapatnam

In the result, appeal of the revenue is dismissed

ITA 204/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam03 Jun 2026AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.204/Viz/2025 (निर्धारणवर्ा/ Assessment Year:2016-17) Vs. M/S. Snf (India) Private Limited Dcit - Circle – 3(1) 19 Jnpc, Ramky Pharmacity Income Tax Office Paravada, Visakhapatnam – 531021 Infinity Towers, Sankarmat Road Andhra Pradesh Visakhapatnam – 530016 Andhra Pradesh [Pan:Aaacp4070A]

Section 142(1)Section 143(2)Section 92C

Since the assessee submitted that it is filing an appeal before the Ld. CIT(A), requested the Ld. AO to pass the final assessment order. The Ld. AO then passed final assessment order under section 143(3) r.w.s. 144C(3) of the Act on 29.01.2020 vide DIN & Order No. ITBA/AST/S/143

Manoj Rajaram Sharma, Thane vs. Commissioner of Income-Tax, Mumbai

In the result, the appeal of the assessee is allowed

ITA 8313/MUM/2025[2020-2021]Status: DisposedITAT Mumbai20 Mar 2026AY 2020-2021

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarmanoj Rajaram Ito - 42(3)(4), Sharma, Mumbai Office No. 615, 6Th Vs. Kautilya Bhawan, C- Floor, Centura Square 41-43, Avenue 3, Near It Park, Sg Barve Videsh Bhavan, G Road, Thane, Block, Bkc, Mumbai Maharashtra-400 604. – 400 051. Pan/Gir No. Bytps1944K (Applicant) (Respondent) Assessee By Shri Suryadev Yadav, Shri Karan Hariya & Shri Prashant Gupta, Ld. Ars Revenue By Shri Bhagirath Ramawat, Ld. Dr Date Of Hearing 17.03.2026 Date Of Pronouncement 20.03.2026

Section 133(6)Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 272A(1)(d)Section 4Section 44A

Assessing Officer initially proposed to estimate income at 8% of total credits, amounting to Rs. 37,10,398/-. 5. However, while passing the final assessment order, the Assessing Officer noted that the assessee had declared income at approximately 35% of gross receipts under section 44AD, which was considered

Swift Impex Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-27, New Delhi

ITA 4923/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 139(1)Section 153CSection 153D

date of document. 26 FEB 2024 Casseisséde Income 1883 ACVT IHANDEWALA EXT. NEW DELHI NEW DELHI Delhi, 110055 3. Copies of the final assessment orders should be forwarded to this office immediately after passing the orders. Proposal for retention of seized material should also be forwarded to this office within

Swift Impex Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-27, New Delhi

ITA 4921/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 139(1)Section 153CSection 153D

digital signature may be taken as date of document. ACVT JHANDEWALAN EXT. NEW DELHI NEW DELHI Delhi, 110055 3. Copies of the final assessment orders should be forwarded to this office immediately after passing the orders. Proposal for retention of seized material should also be forwarded to this office within

Swift Impex Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-27, New Delhi

ITA 4920/DEL/2025[2016-17]Status: DisposedITAT Delhi20 Mar 2026AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 13Section 153CSection 153D

digital signature may be taken as date of document. ACVT IHANDEWALA EXT. NEW DELHI NEW DELHI Delhi, 110055 3. Copies of the final assessment orders should be forwarded to this office immediately after passing the orders. Proposal for retention of seized material should also be forwarded to this office within

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

ITA 2730/DEL/2023[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

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:

For Appellant: Shri Vishal Kalra, Advocate, Ms. Reema GrewalFor Respondent: Shri M.S Nethrapal, CIT-DR
Section 143(3)Section 144CSection 144C(13)

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

ITA 5063/DEL/2025[2014-15]Status: DisposedITAT Delhi19 Mar 2026AY 2014-15

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

Section 143(3)Section 250

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

ITA 5062/DEL/2025[2013-14]Status: DisposedITAT Delhi19 Mar 2026AY 2013-14

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

Section 143(3)Section 250

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

ITA 5061/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Mar 2026AY 2012-13

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

Section 143(3)Section 250

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

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

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. Qua huge claim of advertisement expenses 13. 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. The 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

ITA 5560/DEL/2024[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

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

Section 115JSection 143(1)Section 143(1)(a)Section 143(3)Section 80Section 80ISection 92C

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

ITA 3846/DEL/2023[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

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

Section 143(3)Section 144CSection 144C(8)Section 153Section 282

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

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

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

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

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

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

ITA 3616/DEL/2025[2018-19]Status: DisposedITAT Delhi17 Mar 2026AY 2018-19

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

For Appellant: Sh. Sourav Aggarwal, CAFor Respondent: Sh. S.K. Jadhav, CIT-DR
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 92C

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

Sercel Sa, Dehradun vs. DCIT, Circle-2, Ddn, Dehradun

In the result, the appeal of the assessee is allowed

ITA 59/DDN/2023[2020-21]Status: DisposedITAT Dehradun13 Mar 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 142(1)Section 143(3)Section 195Section 44BSection 9(1)(i)

Hearing 14/01/2026 Date of Pronouncement 13/03/2026 ORDER PER S. RIFAUR RAHMAN, AM 1. This appeal has been filed by the assessee against the final assessment order dated 15.06.2023 passed u/s 143(3) r.w.s.144C(13) of the Income Tax Act, 1961 (hereina"er called ‘the Act’) subsequent to the direc ... submissions of the assessee, the learned DRP sustained the additions made by the assessing officer. Based on the directions of the DRP, the final assessment order was passed. 5. Aggrieved by the above order, the assessee is in appeal before us raising following grounds :- “1. That on the facts

Satyanarayana Murthy Adapa, Rajahmundry vs. ITO., Ward-13(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1263/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia(In आयकर अपीलसं./I.T.A. No.1263/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2017-18) Satyanarayana Murthy Adapa, Vs. Income Tax Officer, Rajahmundry. Ward-13(1), Pan: Aaypa8644C Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Gvn Hari, Advocate (Hybrid Mode) Assessee Represented By राज"वका""त"न"ध"व/ : Ms. Reema Yadav, Sr. Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 05/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 13/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Satyanarayana Murthy Adapa (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 16/06/2025 For The A.Y. 2017-18. Satyanarayana Murthy Adapa Vs. Ito 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 115BSection 127Section 143(2)

Hyderabad placed at page Nos. 9 and 10 of the paper book and submitted that the said officer ultimately passed the final assessment order. Accordingly, the Ld. AR submitted that the jurisdiction exercised by ACIT Circle- 13(1), Hyderabad is not valid, as the said officer has not issued

Nathan Anil Rao, Mumbai vs. The ITO -Circle 23(1), Mumbai

In the result, appeal of the assessee is allowed for statistical

ITA 8666/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Vijaykumar Soni, CIT DRFor Respondent: Shri Nikhil Tiwari
Section 143(2)Section 68Section 69

Appellant; provided by the Appellant; Ld. AO has exceeded his j ceeded his jurisdiction 3. erred in exceeding jurisdiction by passing the final assessment order after 3. erred in exceeding jurisdiction by passing the final assessment order after 3. erred in exceeding jurisdiction by passing the final assessment order after

Getinge Medical India Private Limited, Mumbai vs. DCIT 2(2)(1), Mumbai Maharashtra

In the result, appeal filed by the assessee stands partly allowed

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

Hearing 21.01.2026 Date of Pronouncement 13.03.2026 ORDER Per: Smt. Beena Pillai, J.M.: Present appeal filed by the assessee arises out of the final assessment order dated 23.07.2024 passed by the NFAC for Assessment Year 2020-21 on following grounds of appeal: 2 Getinge Medical India Private Limited “1. Ground ... grounds raised therein and upheld the proposed addition made by the Ld. AO/TPO. Upon receipt of the DRP directions, the Ld.AO passed the final assessment order being the impugned order. The Ld. AO while computing the tax on the income, adopted normal rates as against the concessional rate opted