“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

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

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

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

Visteon Corporation, Michigan vs. DCIT International Taxation, Circle 2(2), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 260/CHNY/2023[2015-16]Status: DisposedITAT Chennai26 Jul 2024AY 2015-16

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.:259, 260, 261 & 262/Chny/2023 िनधा"रण वष"/Assessment Years:2014-15, 2015-16, 2016-17 & 2017-18 & S.A. Nos. 28, 29 & 30/Chny/2023 [In Ita Nos. 259, 261 & 262/Chny/2023] M/S. Visteon Corporation, The Deputy Commissioner Grace Lake Corporation Centre, Vs. Of Income Tax, Van Buren Township, International Taxation, Michigan - 48111 Circle 2(2), Chennai. Pan: Aadcv 5660K (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Ajay Vohra, Sr. Advocate (By Virtual) Shri Aditya Vohra, Advocate ""यथ" क" ओर से/Respondent By : Shri Nilay Bara Som, Cit सुनवाई क" तारीख/Date Of Hearing : 01.07.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.07.2024 आदेश /O R D E R Per Mahavir Singh: These Three Appeals By The Assessee In Ita Nos.259, 261 & 262/Chny/2023 Are Arising Out Of The Final Assessment Orders Passed By The Assistant Commissioner Of Income Tax, International Taxation Circle 2(2), Chennai Vide Orders Of Even Date 06.01.2023 In Pursuant To The Directions Of The Dispute Resolution Panel-2

For Appellant: Shri Ajay Vohra, Sr. Advocate (By Virtual)For Respondent: Shri Nilay Bara Som, CIT

Section 142(1)Section 263

MAHAVIR SINGH, VICE PRESIDENT: These three appeals by the assessee in ITA Nos.259, 261 & 262/CHNY/2023 are arising out of the final assessment orders passed by the Assistant Commissioner of Income Tax, International Taxation Circle 2(2), Chennai vide orders of even date 06.01.2023 in pursuant to the directions

Visteon Corporation, Michigan vs. DCIT, Intenl Taxn, Circle-2(2), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 259/CHNY/2023[2014-15]Status: DisposedITAT Chennai26 Jul 2024AY 2014-15

For Appellant: Shri Ajay Vohra, Sr. Advocate (By Virtual)For Respondent: Shri Nilay Bara Som, CIT

Section 142(1)Section 263

Bhs India Holdings, Inc., New Jersey, Usa vs. Assistant Commissioner of Income Tax, Circle International Taxation 1(1)(2), Delhi

The appeal is allowed and the stay application which is tagged along is dismissed being infructous

ITA 3286/DEL/2023[2021-22]Status: DisposedITAT Delhi26 Jul 2024AY 2021-22

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT( DR)

Section 143(3)Section 144G(13)

analysis of the documents as mentioned above. Ground numbers 3 to 8 are accordingly disposed of.” 7. The AO however passed the final assessment order treating the income from sale of shares as ‘income from other sources’. 7.1 Aggrieved by the impugned order, the Appellant has preferred this appeal raising ... from non-compliance with principles of equity and natural Justice. The directions issued by the Hon'ble DRP without valid DIN and the final assessment order passed under section 143(3) read with section 144C(13) of the Act are bad and invalid in law 3 The directions issued

Ncr Global Solutions Limited, Ireland vs. Deputy Commissioner of Income-Tax, Circle 2(2)(2), International Tax, New Delhi

In the result, the grounds are sustained and the appeal filed by the Assessee is allowed

ITA 3230/DEL/2023[2021-22]Status: DisposedITAT Delhi26 Jul 2024AY 2021-22

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2021-22 Ncr Global Solutions Limited, Vs Dcit, Lakeview Drive, Circle 2(2)(2), Airside Business Park, International Taxation, Swords, Co. Dublin, K67 N2N9, New Delhi. Ireland. Pan: Aadcn5762E (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao & Ms Viyushti Rawat, Advocate Revenue By : Shri Vizay B. Vasanta, Cit-Dr Date Of Hearing : 25.07.2024 Date Of Pronouncement : 26.07.2024 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 09.08.2023 Of The Dispute Resolution Panel-2, New Delhi (Hereinafter Referred To As ‘The Ld. Drp’) In Objection No.220 Dated 20.01.2023 Arising Out Of The Objection Before It Against The Order Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), By The Dcit, Circle International Taxation 2(2)(2), New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Nageshwar Rao &For Respondent: Shri Vizay B. Vasanta, CIT-DR

Section 142(1)Section 143(3)

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 20 September 2023 ("impugned order”) issued under Section 143(3) read with Section 144C(13) of the Act passed by Ld, Deputy Commissioner ... without bearing DIN on the body of such order, without recording reasons for not doing so renders same and subsequent final assessment order passed pursuant thereto are invalid and deemed to have never been issued as per CBDT Circular 19/2019 dated 14 August 2019. 2. Impugned order erred in making

DCIT(International Taxation), Delhi vs. Kesav Sree Kumar Kesavan Nair, Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 2849/DEL/2023[2016-17]Status: DisposedITAT Delhi26 Jul 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Amit Sharma, AdvFor Respondent: Shri Mithun N. Shate, Sr. DR

Section 144BSection 144CSection 147Section 69Section 69C

mandatory requirement of Section 144C (1) of the Act and first pass a draft assessment order would result in invalidation of the final assessment order and the consequent demand notices and penalty proceedings. 17. For the aforementioned reasons, the final assessment orders dated 31st March, 2015 passed ... same is reproduced as under: “7. In the instant case, it an undisputed fact that the Assessing Officer has passed the final assessment order on 31/12/2019 without passing draft assessment order. Following the decision of Co-ordinate Bench, on parity of facts and reasons we hold the assessment order

DCIT, International Taxation Circle-2(1)2, Delhi vs. Kesav Sree Kumar Kesavan Nair, Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 2848/DEL/2023[2015-16]Status: DisposedITAT Delhi26 Jul 2024AY 2015-16

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Amit Sharma, AdvFor Respondent: Shri Mithun N. Shate, Sr. DR

Section 144BSection 144CSection 147Section 69Section 69C

Tiger Global Eight Holdings, Mauritius vs. DCIT Intl. Taxation Circle 3(1)(1), New Delhi

ITA 2345/DEL/2023[2020-2021]Status: DisposedITAT Delhi26 Jul 2024AY 2020-2021

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2020-21 Tiger Global Eight Holdings, Vs Dcit, C/O 202 Rajnigandha International Taxation, Apartment, Circle 3(1)(1), Prof. V.S. Agashe Path, New Delhi. Dadar (West), Mumbai 400 028, Maharashtra. Pan: Aafct0276M (Appellant) (Respondent) Assessee By : Shri Porus Kaka, Sr. Advocate; Shri Manish Kant, Advocate; & Ms Amrita Shenoy & Hetal Jakharia, Cas Revenue By : Shri Vizay B. Vasanta, Cit-Dr Date Of Hearing : 25.07.2024 Date Of Pronouncement : 26.07.2024 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR

Section 144C(13)

Article 13(4) of India-Mauritius DTAA. To which the AO had denied the treaty benefit. The DRP had sustained same and accordingly final assessment order was passed, which is under challenge by raising following grounds; 3. We find that in DRP order all the relevant aspects as discussed

R1 Rcm Holdco Inc. (Formerly Known As R1 Rcm Inc.), Usa vs. DCIT, Int. Taxation, Gurgaon

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

ITA 2044/DEL/2023[2020-21]Status: DisposedITAT Delhi26 Jul 2024AY 2020-21

Bench: SHRI G.S. PANNU, HON'BLE (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri S.K. Aggarwal, CAFor Respondent: Shri Vijay B. Vasanta, CIT-DR

Section 143(3)Section 9(1)(vi)Section 92C

Date of Hearing : 25.07.2024 Date of Pronouncement : 26.07.2024 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the final assessment order dated 26.05.2023 passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’), by the ACIT, International Taxation ... Income- Tax Act, 1961 (the ‘Act’) and the India-USA Double Taxation Avoidance Agreement (‘DTAA’), based on the findings made in the final assessment order. In doing so: a. The Ld. AO has erred in holding that the charges received by the Appellant from its AE on actual usage basis

Fare Portal India Private Limited, New Delhi vs. DCIT, Circle-7(1), Delhi

In the result, the appeal of the assessee in ITA No

ITA 497/DEL/2022[2017-18]Status: DisposedITAT Delhi26 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Himanshu S. SinhaFor Respondent: Shri Mahesh Shah

Section 143(3)Section 92CSection 92C(3)Section 92D

adjustment of Rs.2,81,888/- on account of interest on delayed collection of receivables vide order dated 26/02/2022. 6. Aggrieved by the final Assessment Order dated 26/02/2022 the assessee has preferred the present Appeal on grounds mentioned above. 7. The Ground No. 1 of the Assessee is general in nature

Goodyear India Ltd., Faridabad vs. DCIT, Circle-10(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 346/DEL/2022[2017-18]Status: DisposedITAT Delhi26 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vivek Verma CIT (DR ) and Sh. Kanv Bali, Sr. DR

Section 143(3)Section 144BSection 144CSection 92B

assessee. The issues involved in the proposed variation are finalized by the A.O as per the directions issued by the Ld. DRP. A final assessment order came to be passed u/s 143(3) read with Section 144C, read with 144B of the Income Tax Act vide order dated 27/01/2022 ... Income 255,67,96,909 Total Assessed Income 255,67,96,910 Rounded off u/s 288A of I.T. Act ” 5. Aggrieved by the final assessment order dated 27/01/2022, the assessee preferred the present appeal on the grounds mentioned above. Goodyear India Ltd. 6. Ground No. 1-1.2 are general

Mixpanel Inc., Usa vs. ACIT Circle- 2(2)(1) Int.Taxation., New Delhi

The appeal is allowed

ITA 1996/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Jul 2024AY 2018-19

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Shri Kamal Sawhney, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT(DR)

Section 143(2)Section 143(3)Section 144C(13)

learned Assistant Commissioner of Income Tax, Circle 2(2)(1) (International tax), New Delhi ('Ld. AO') has erred in passing the final assessment order dated May 20, 2022 (received on 29.06.2022) under section 143(3) read with section 144C of the Income ... section 144C of the Act, on the following grounds. 1. On the facts and circumstances of the case and in law, the final assessment order passed by the learned AO as per the directions of the Hon'ble DRP is bad-in-law and liable to be quashed

Goodyear India Ltd, Faridabad vs. ACIT, Circle-10(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1451/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Jul 2024AY 2018-19

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vivek Verma CIT (DR ) and Sh. Kanv Bali, Sr. DR

Section 143(3)Section 144BSection 144CSection 92B

Itochu Corporation, Japan vs. ACIT (International Taxation), Circle-2(1)(1), New Delhi

The appeal is allowed

ITA 760/DEL/2021[2017-18]Status: DisposedITAT Delhi26 Jul 2024AY 2017-18

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT( DR)

Section 143(2)Section 143(3)Section 144C

Date of Hearing : 25.04.2024 Date of Pronouncement : .07.2024 ORDER PER ANUBHAV SHARMA, JM This appeal is preferred by the assessee against the final assessment order dated 16.04.2021 passed by the Assessing Officer, Circle International Taxation 2(1)(1) (hereinafter referred to as the Ld. AO) u/s 143(3) r.w.s. 144C ... appeal before us and has raised following grounds; “1. On the facts and in the circumstances of the case & in law, the final assessment order passed by the Ld. AO is bad in law and void ab initio. Page 11 of 36 ITOCHU Corporation 2. On the facts

Aurobindo Pharma Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, appeal of the Revenue is dismissed and the appeal of the assessee is allowed in part

ITA 352/HYD/2023[2017-18]Status: DisposedITAT Hyderabad25 Jul 2024AY 2017-18

Bench: Shri Manjunatha, G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 352/Hyd/2023 (निर्धारण वर्ा / Assessment Year: 2017-18)

For Appellant: Adv. B.G. ReddyFor Respondent: Shri Kumar Pranav,CIT( DR)

Section 35Section 92B

which the learned Assessing Officer passed the draft assessment order. Assessee reported no objection for passing the final order pursuant to which the final assessment order was passed, which was challenged before the learned CIT(A). Learned CIT(A), by way of impugned order disposed of the appeal giving part

ACIT, Central Circle-1(2), Hyderabad vs. Aurobindo Pharma Limited, Hyderabad

In the result, appeal of the Revenue is dismissed and the appeal of the assessee is allowed in part

ITA 321/HYD/2023[2017-18]Status: DisposedITAT Hyderabad25 Jul 2024AY 2017-18

Bench: Shri Manjunatha, G. & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 352/Hyd/2023 (निर्धारण वर्ा / Assessment Year: 2017-18)

For Appellant: Adv. B.G. ReddyFor Respondent: Shri Kumar Pranav,CIT( DR)

Section 35Section 92B

Piramal Enterprises Limited, Mumbai vs. Principal Commissioner of Income Tax Mumbai - 8, Mumbai

In the result, appeal of the assessee is allowed

ITA 2896/MUM/2024[2017-18]Status: DisposedITAT Mumbai25 Jul 2024AY 2017-18

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Ronak Doshi a/w Priyank Gala, A/RsFor Respondent: Ms. Madhu Malati Ghosh, CIT, D/R

Section 263

also restrained form issuing any direction. In such circumstances, the Ld. Assessing Officer could not have proceeded in passing this final assessment order. Once the draft assessment order passed itself has been set aside, in absence of which final assessment order passed is also not sustainable in law. Accordingly

Bestseller Fashion India Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, 9(2)(1), Mumbai

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

ITA 5140/MUM/2017[2011-12]Status: DisposedITAT Mumbai25 Jul 2024AY 2011-12

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Bestseller Fashion India Private Limited Asst. Cit-9(2)(1) The Lalit Residency, 1St Floor, Mumbai Vs. Lalit Hotelsahar Airport Road, Andheri (E), Mumbai-400 059 Pan/Gir No. Aaecb 2906 M (Assessee) : (Respondent) : Shri Jabir Contractor Assessee By Respondent By : Shri Ashish Kumar Agrawal Date Of Hearing : 29.04.2024 Date Of Pronouncement : 25.07.2024

For Respondent: Shri Ashish Kumar Agrawal

Section 143(1)Section 143(2)Section 143(3)Section 144C(1)Section 92C

passed the draft assessment order u/s. 144C(1) of the Act dated 24.03.2014 and subsequently the final assessment order dated 08.05.2015 passed u/s. 143(3) r.w.s. 144C(3)(b) of the Act determining a loss at Rs.1,64,39,930/- after making an addition of Rs.1,43,48,901/- being

Berlian Mcdermott Sdn. Bhd., Noida vs. Ac, Circle 1(1)(2), International Taxation, New Delhi

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

ITA 479/DEL/2023[2020-21]Status: DisposedITAT Delhi25 Jul 2024AY 2020-21

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.479/िद"ी/2023 (िन.व. 2020-21) Berlian Mcdermott N. Bhd. C/O Nangia & Co. Llp, A-109, Sector-136, Noida, Up 201304 Pan: Aagcb-6291-H ...... अपीलाथ"/Appellant बनाम Vs. Assistant Commissioner Of Income Tax Circle 1(1)(2), International Taxation, ..... "ितवादी/Respondent New Delhi 110002

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vijay B Vasanta, CIT-DR

Section 143(3)Section 144CSection 44B

dated 02.12.2022 issued by the DRP which is in direct contradiction to the mandate of section 144C of the Act and hence the final assessment order dated 17.01.2023 passed by the Assessing Officer is illegal, bad in law and without jurisdiction." 3.1. The ld. Counsel submitted that the aforesaid additional ... Counsel for the assessee submits that the Assessing Officer (AO) has failed to follow binding directions of the DRP while passing the final assessment order. Therefore, the assessment order is liable to be quashed. The ld. Counsel submits that the Assessing Officer while passing the draft assessment order made addition

Braino Brain Kids Academy P Ltd., Chennai vs. DCIT Corp Circle 1(1), Chennai

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

ITA 1447/CHNY/2024[2019-20]Status: DisposedITAT Chennai24 Jul 2024AY 2019-20

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1447/Chny/2024 िनधा"रण वष" / Assessment Year: 2019-2020 Braino Brain Kids Academy P Ltd., The Deputy Commissioner Of Temple Tower, 2Nd Floor, V. Income Tax, 672 Anna Salai, Cit Nagar, Corporate Circle -1(1), Nandanam, Chennai – 600 035. Chennai – 34. [Pan: Aaccb-6355-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. M. Karunakaran, Advocate ""यथ" क" ओर से/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई की तारीख/Date Of Hearing : 22.07.2024 घोषणा की तारीख/Date Of Pronouncement : 24.07.2024

For Appellant: Shri. M. Karunakaran, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar, CIT

Section 143(1)Section 90

present case. In the present case, the returns were filed without FTC, however the same was filed before passing of the final assessment order. The filing of FTC in terms of the Rule 128 is only directory in nature. The rule is only for the implementation of the provisions ... petitioner on 02.02.2021. The respondent is directed to give due credit to the Kenya income of the petitioner and pass the final assessment order. Further, it is made clear that the impugned order is set aside only to the extent of disallowing of FTC claim made by the petitioner

Cosmos Maya India Pvt Ltd, Mumbai vs. Central Processing Center, ITO-16(1)(3), Bengaluru

In the result, appeal of the assessee is allowed

ITA 2543/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Jul 2024AY 2021-22

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Prakash Jhunjhunwala, A/RsFor Respondent: Shri Akshay Tapadiya, Sr. D/R

Section 143(1)