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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

Kunal Ramesh Shah, Mumbai vs. ADIT CPC Bangaluru, Bangaluru

In the result, appeal of the assessee is allowed

ITA 2502/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jul 2024AY 2020-21

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

For Appellant: Shri Ravi Dasija, C.A. & Kiran Mehta, C.A., A/RsFor Respondent: Shri Sunil K. Agwane, Sr. D/R
Section 143(1)

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

Benetton India P.Ltd, Gurgaon vs. ACIT, Circle-4(2), New Delhi

ITA 496/DEL/2022[2017-18]Status: DisposedITAT Delhi24 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 496/Del/2022 (A.Y 2017-18) Benetton India Pvt. Ltd., Asstt. Commissioner Of Income Plot No. 25B, Block Infocity Vs. Tax, Circle : 4 (2), Sector : 34, Gurugram, New Delhi. Haryana.Pan:Aaacd1013F (Appellant) (Respondent) Assessee By : Shri Deepak Chopra, H. S. Ajmani, Sh. Ankul Goel & Ms. Rashi Khanna, Advs Department By: Shri Mahesh Shah, [Cit] D.R. & Sh. Kanv Bali, Sr. Dr

For Appellant: Shri Deepak Chopra, H. S. Ajmani, ShFor Respondent: Shri Mahesh Shah
Section 143(3)Section 144BSection 144CSection 144C(13)

respect of various objections of the assessee at appropriate places in the final order. In compliance with directions of the DRP, the final assessment order came to be passed on 25/02/2022 u/s 143(3) read with Section 144C(13) and Section 144B of the Act. Benetton India P. Ltd., Gurgaon ... Aggrieved by the final assessment order dated 25/02/2022, the assessee has preferred the present appeal on the grounds mentioned above. 9. The Ground No. 1 & 2 are general in nature which requires no separate adjudication. 10. The Ground No. 3 and its sub grounds pertain to addition

ACIT, Circle- 27(2), New Delhi vs. Wrigley India Pvt. Ltd., New Delhi

ITA 7440/DEL/2017[2012-13]Status: DisposedITAT Delhi24 Jul 2024AY 2012-13

Bench: or at the time of hearing of the appeal.”

Section 142(3)Section 143(1)Section 143(2)Section 143(3)Section 144CSection 144C(1)

with Section 144C(1) of the Act by assessing the loss of the assessee at Rs. 17,15,08,023/-. The final assessment order came to be passed on 27/04/2016 u/s 143(3) of the Act read with 4 ACIT Vs. Wrigley India Pvt. Ltd. Section 144C ... Revenue preferred the present Appeal on the Grounds mentioned above. 5. The Ld. Departmental Representative relying on the order of the TPO and final assessment order sought for allowing the Grounds of Appeal of the Revenue and brought the relevant facts to our notice. 6. Per contra, the Ld. Assessee

ACIT, Circle-4(2), New Delhi vs. Benetton India P.Ltd, Gurgaon

ITA 7389/DEL/2017[2010-11]Status: DisposedITAT Delhi24 Jul 2024AY 2010-11

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 496/Del/2022 (A.Y 2017-18) Benetton India Pvt. Ltd., Asstt. Commissioner Of Income Plot No. 25B, Block Infocity Vs. Tax, Circle : 4 (2), Sector : 34, Gurugram, New Delhi. Haryana.Pan:Aaacd1013F (Appellant) (Respondent) Assessee By : Shri Deepak Chopra, H. S. Ajmani, Sh. Ankul Goel & Ms. Rashi Khanna, Advs Department By: Shri Mahesh Shah, [Cit] D.R. & Sh. Kanv Bali, Sr. Dr

For Appellant: Shri Deepak Chopra, H. S. Ajmani, ShFor Respondent: Shri Mahesh Shah
Section 143(3)Section 144BSection 144CSection 144C(13)

respect of various objections of the assessee at appropriate places in the final order. In compliance with directions of the DRP, the final assessment order came to be passed on 25/02/2022 u/s 143(3) read with Section 144C(13) and Section 144B of the Act. Benetton India P. Ltd., Gurgaon ... Aggrieved by the final assessment order dated 25/02/2022, the assessee has preferred the present appeal on the grounds mentioned above. 9. The Ground No. 1 & 2 are general in nature which requires no separate adjudication. 10. The Ground No. 3 and its sub grounds pertain to addition

Aurobindo Pharma Limited, Hyderabad Knowledge City 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 351/HYD/2023[2016-17]Status: DisposedITAT Hyderabad23 Jul 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No. 320/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Acit, Central Circle 1(2) Vs. Aurobindo Pharma Ltd Hyderabad Hyderabad [Pan : Aabca7366H] आ.अपी.सं / Ita No. 351/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Aurobindo Pharma Ltd Vs. Acit, Central Circle 1(2) Hyderabad Hyderabad Pan: Aabca7366H अपीलाथ" / Appellant "" यथ" / Respondent राज" व "ारा/Revenue By: Shri M Vijay Kumar, Cit(Dr) िनधा"रती "ारा/Assessee By: Advocate Bg Reddy

For Appellant: Advocate BG ReddyFor Respondent: Shri M Vijay Kumar, CIT(DR)
Section 35

learned Assessing Officer passed the dra" assessment order. Assessee reported no objec"on 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 relief

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 320/HYD/2023[2016-17]Status: DisposedITAT Hyderabad23 Jul 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No. 320/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Acit, Central Circle 1(2) Vs. Aurobindo Pharma Ltd Hyderabad Hyderabad [Pan : Aabca7366H] आ.अपी.सं / Ita No. 351/Hyd/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Aurobindo Pharma Ltd Vs. Acit, Central Circle 1(2) Hyderabad Hyderabad Pan: Aabca7366H अपीलाथ" / Appellant "" यथ" / Respondent राज" व "ारा/Revenue By: Shri M Vijay Kumar, Cit(Dr) िनधा"रती "ारा/Assessee By: Advocate Bg Reddy

For Appellant: Advocate BG ReddyFor Respondent: Shri M Vijay Kumar, CIT(DR)
Section 35

learned Assessing Officer passed the dra" assessment order. Assessee reported no objec"on 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 relief

Rapiscan Systems Inc, United States vs. ADIT, (International Taxation)-2, Hyderabad

In the result, appeals of the assessee are allowed

ITA 588/HYD/2022[2019-20]Status: DisposedITAT Hyderabad23 Jul 2024AY 2019-20

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: Shri M P Lohia (Virtual)For Respondent: Shri Kumar Pranav CIT(DR)

assessee preferred these appeals. 2. The common ques"on that arises for our considera"on in these two appeals is whether the final assessment orders that were passed on 29/8/2022 for the assessment years 2018-19 and 2019-20 pursuant to the direc"ons that were issued and uploaded ... physical copy of direc"ons was also sent to the learned Assessing Officer on 30/6/2022 through speed post. Learned Assessing Officer, however, passed final assessment order under sec"on 143(3) read with sec"on 144C (13) of the Act on 29/8/2022. 3. By way of addi"onal grounds assessee

Rapiscan Systems Inc, United States vs. ADIT, (International Taxation)-2, Hyderabad

In the result, appeals of the assessee are allowed

ITA 587/HYD/2022[2018-19]Status: DisposedITAT Hyderabad23 Jul 2024AY 2018-19

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: Shri M P Lohia (Virtual)For Respondent: Shri Kumar Pranav CIT(DR)

assessee preferred these appeals. 2. The common ques"on that arises for our considera"on in these two appeals is whether the final assessment orders that were passed on 29/8/2022 for the assessment years 2018-19 and 2019-20 pursuant to the direc"ons that were issued and uploaded ... physical copy of direc"ons was also sent to the learned Assessing Officer on 30/6/2022 through speed post. Learned Assessing Officer, however, passed final assessment order under sec"on 143(3) read with sec"on 144C (13) of the Act on 29/8/2022. 3. By way of addi"onal grounds assessee

Corteva Agriscience Services India Private Limited, Hyderabad vs. DCIT, Circle-17(1), Hyderabad

In the result, the Ground No

ITA 253/HYD/2017[2011-12]Status: DisposedITAT Hyderabad23 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Sandeep Bansal, CA and Shri Rohit Mittal, CAFor Respondent: : Shri Shakeer Ahamed, DR
Section 143(3)Section 144C(4)Section 92C

dated 30 November 2016 issued by the learned Commissioner of Income-tax (Appeals) - 5, Hyderabad ['CIT(A)'] pursuant to an appeal against the final assessment order dated 07 May 2016 passed by the Deputy Commissioner of Income-tax, Circle - 17(1), Hyderabad (`A0') u/s 143(3) read with section 144C

Cap Gemini Technology Services India Limited(Formerly Known As Igate Global Solution Limited)-M/S Patni Telecom Solutions Pvt Ltd, Changed Name to M/S.Igate Information Services Private Limited Merged With Igate Global Solutions Limited, Hyderabad vs. ITO, Ward - 2(1), Hyderabad

In the result, appeal raised by the assessee is dismissed

ITA 446/HYD/2015[2010-11]Status: DisposedITAT Hyderabad23 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.446/Hyd/2015 (िनधा"रण वष"/Assessment Year: 2010-11) Cap Gemini Vs. Income Tax Officer Technology Services Ward 2(1) India Ltd(Formerly Igate Hyderabad Global Solutions Ltd) Hyderabad Pan:Aacca4255G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate A.V. Raghuram राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 04/07/2024 घोषणा की तारीख/Pronouncement: 23/07/2024 आदेश/Order

For Appellant: Advocate A.V. RaghuramFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 10ASection 143(3)Section 92C(2)

appreciating that these are purely recovery of expenses from the associated enterprises at cost without any mark up. 10. While passing the final assessment order u/s. 143(3) r.w.s. 92CA(3) & 144C the learned Assessing Officer erred in setting off the profits of Rs.7,69,85,754 of Pune STPI ... Supreme Court in the case of CIT vs. Yokogawa India Ltd reported in (2017) 391 ITR 274 (S.C). 15. Aggrieved with such final assessment order assessee is in appeal before the Tribunal. 16. During the course of arguments, the ld.AR has made submissions in respect of comparables which are captured

Charies River Laboratories Montreal, Ulc, Canada vs. ACIT, Circle- 1(2)(1) Int. Taxation, New Delhi

ITA 2324/DEL/2022[2019-20]Status: DisposedITAT Delhi23 Jul 2024AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2019-20 Charles River Laboratories Vs Acit, Montreal, Ulc, Circle-1(2)(1), 22022 Transcanadienenne, International Taxation, Quebec, Senneville, New Delhi. Canada-H9X3R3, Canada. Pan: Aagcc4061J (Appellant) (Respondent) Assessee By : Shri Chavali S. Narayana, Ca Revenue By : Shri Vizay B. Vasanta, Cit-Dr Date Of Hearing : 25.04.2024 Date Of Pronouncement : 23.07.2024

For Appellant: Shri Chavali S. Narayana, CAFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 142(1)Section 143(3)

Date of Hearing : 25.04.2024 Date of Pronouncement : 23.07.2024 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the final assessment order dated 29.07.2022 passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’), by the ACIT, Circle International

Mahavir Singh, New Delhi vs. ITO, Ward-8(2), New Delhi

ITA 8602/DEL/2019[2015-16]Status: DisposedITAT Delhi23 Jul 2024AY 2015-16

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

For Appellant: Shri R.R. Singhla, CAFor Respondent: Shri Anshul, Sr. DR
Section 10(38)Section 127Section 142(1)Section 143(2)Section 143(3)

Ward 40(1), Delhi, even to say on request of assessee, the same ultimately, reached Ward 8(2), Delhi, from where the final assessment order was passed. We are of the considered view that even if it is assumed that in accordance with the order dated

Macromill Research India LLP (Formerly Market Tools Research P. Ltd., Hyderabad vs. ACIT, Cirlce-16(2), Hyderabad

ITA 501/HYD/2016[2011-12]Status: DisposedITAT Hyderabad22 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

LALIET KUMAR, J.M.: This bunch of four appeals, two by assessee and two by Revenue are directed against separate, but identical final assessment orders dt.28.10.2014 and 29.01.2016 passed by the Assistant Commissioner of Income Tax, Circle 16(2), Hyderabad for the assessment years 2010-11 and 2011-12, respectively. Since ... Income Tax Act dated 31-10-2013, determined the ALP for these international transactions at Rs.7,24,90,047/-. Following this, a 7 final assessment order u/s 143(3) read with Section 92CA(3) and Section 144C was issued on 23.12.2013. Subsequently, the assessee appealed to the Dispute Resolution Panel

ACIT, Cirlce-5 (1), Hyderabad vs. Market Tools Research Private Limited, Hyderabad

ITA 424/HYD/2016[2011-12]Status: HeardITAT Hyderabad22 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

LALIET KUMAR, J.M.: This bunch of four appeals, two by assessee and two by Revenue are directed against separate, but identical final assessment orders dt.28.10.2014 and 29.01.2016 passed by the Assistant Commissioner of Income Tax, Circle 16(2), Hyderabad for the assessment years 2010-11 and 2011-12, respectively. Since ... Income Tax Act dated 31-10-2013, determined the ALP for these international transactions at Rs.7,24,90,047/-. Following this, a 7 final assessment order u/s 143(3) read with Section 92CA(3) and Section 144C was issued on 23.12.2013. Subsequently, the assessee appealed to the Dispute Resolution Panel

ACIT., Circle-5(1), Hyderabad vs. Market Tools & Research Private Limited, Hyderabad

ITA 1935/HYD/2014[2010-11]Status: HeardITAT Hyderabad22 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

LALIET KUMAR, J.M.: This bunch of four appeals, two by assessee and two by Revenue are directed against separate, but identical final assessment orders dt.28.10.2014 and 29.01.2016 passed by the Assistant Commissioner of Income Tax, Circle 16(2), Hyderabad for the assessment years 2010-11 and 2011-12, respectively. Since ... Income Tax Act dated 31-10-2013, determined the ALP for these international transactions at Rs.7,24,90,047/-. Following this, a 7 final assessment order u/s 143(3) read with Section 92CA(3) and Section 144C was issued on 23.12.2013. Subsequently, the assessee appealed to the Dispute Resolution Panel

Macromill Research India LLP (Formerly Market Tools Research Private Limited), Hyderabad vs. ACIT., Circle-16(2), Hyderabad

ITA 1866/HYD/2014[2010-11]Status: DisposedITAT Hyderabad22 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

LALIET KUMAR, J.M.: This bunch of four appeals, two by assessee and two by Revenue are directed against separate, but identical final assessment orders dt.28.10.2014 and 29.01.2016 passed by the Assistant Commissioner of Income Tax, Circle 16(2), Hyderabad for the assessment years 2010-11 and 2011-12, respectively. Since ... Income Tax Act dated 31-10-2013, determined the ALP for these international transactions at Rs.7,24,90,047/-. Following this, a 7 final assessment order u/s 143(3) read with Section 92CA(3) and Section 144C was issued on 23.12.2013. Subsequently, the assessee appealed to the Dispute Resolution Panel

Sunil Chablani, Ajmer, Rajasthan vs. Circle (Intl Tax), Jaipur, Rajasthan

ITA 68/JPR/2024[2018-19]Status: DisposedITAT Jaipur22 Jul 2024AY 2018-19
For Appellant: Shri Mahendra Gargieya &For Respondent: Shri Anil Dhaka (CIT-DR)
Section 144Section 144CSection 144C(5)Section 147Section 148Section 234ASection 45

Assessing Officer shall also place a copy of the Panel Directions as Annexure to the final order." In compliance to the said directions, final assessment order was passed u/s 147 r.w.s. 144 on 29.12.2023 determining total income at Rs. 69,90,000/. As the Id. DRP has directed to pass

Sanjay Manoharlal Narang, Mumbai vs. Int Tax Ward - 3 (3) (1), Mumbai

In the result, the appeal of the learned assessing officer is dismissed

ITA 3180/MUM/2023[2020-21]Status: DisposedITAT Mumbai22 Jul 2024AY 2020-21

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm The Assistant Commissioner Of Vs. De Beers U K Limited Income Tax ( International C/O S R Batliboi & Co Taxation 2(1) (1) Mumbai 14Th Floor 17Th Floor Air India Building The Ruby Nariman Point 29, Senapati Bapatmarg Mumbai Dadar W Mumbai (Appellant) (Respondent) Pan No. Aacct5530B

For Appellant: Shri Pranay GandhiFor Respondent: Shri Anil Sant , SR DR
Section 143Section 144C

head of fees for technical services and royalty and taxed accordingly. According with that draft assessment order was passed on 9/12/2016. 6. Similarly, final assessment order under section 143 (3) read with section 144C was also passed on 14/2/2017 as the assessee submitted that it is opting not to file

Rachna Narang, Mumbai vs. Int Tax Ward - 3 (3) (1), Mumbai

In the result, the appeal of the learned assessing officer is dismissed

ITA 3179/MUM/2023[2020-21]Status: DisposedITAT Mumbai22 Jul 2024AY 2020-21

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm The Assistant Commissioner Of Vs. De Beers U K Limited Income Tax ( International C/O S R Batliboi & Co Taxation 2(1) (1) Mumbai 14Th Floor 17Th Floor Air India Building The Ruby Nariman Point 29, Senapati Bapatmarg Mumbai Dadar W Mumbai (Appellant) (Respondent) Pan No. Aacct5530B

For Appellant: Shri Pranay GandhiFor Respondent: Shri Anil Sant , SR DR
Section 143Section 144C

head of fees for technical services and royalty and taxed accordingly. According with that draft assessment order was passed on 9/12/2016. 6. Similarly, final assessment order under section 143 (3) read with section 144C was also passed on 14/2/2017 as the assessee submitted that it is opting not to file

Emirates, Mumbai vs. DCIT (International Tax), Circle-2(2)(1), Mumbai

In the result appeal of the assessee is dismissed

ITA 4635/MUM/2023[2021-22]Status: DisposedITAT Mumbai18 Jul 2024AY 2021-22

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

For Appellant: Shri Hardik Nirmal, A/RFor Respondent: Shri Anil Sant, Addl. CIT, D/R
Section 143(3)

relative smallness of the amounts involved, the Appellant has decided to withdraw the captioned appeal filed before the Hon'ble Tribunal against the final assessment order. I.T.A. No. 4635/Mum/2023 2 Be that as it may, it is most humbly submitted that the withdrawing of the captioned appeal should