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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

Siemens Aktiengesellschaft, Mumbai vs. DDIT (It) 2(1), Mumbai

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

ITA 2153/MUM/2014[2009-10]Status: DisposedITAT Mumbai07 Jun 2024AY 2009-10

Bench: SHRI B R BASKARAN (Accountant Member), SHRI AMIT SHUKLA (Judicial Member)

Section 144CSection 144C(5)Section 153Section 9(1)(vi)

AMIT SHUKLA (J.M): The aforesaid cross appeals have been filed by the assessee as well as by the department against final assessment order dated 30/01/2014, passed by Dy. Director Income Tax (IT)-2(1), Mumbai in pursuance of directions given by the DRP vide order dated 16/12/2013 u/s.144C ... barred by Additional ground no. 2 limitation under section 153 of filed on 24 November 2022 the Income-tax Act, 1961. 3. Final assessment order contrary Additional ground no. 3 to directions of DRP is invalid. filed on 1 7 January 2024 4. The assessee is a non-resident company

Tata Steel Ltd, Mumbai vs. Addl CIT 2(3), Mumbai

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

ITA 8707/MUM/2011[2007-08]Status: DisposedITAT Mumbai07 Jun 2024AY 2007-08

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri J. D. Mistry a/wFor Respondent: Shri P. C. Chhotaray
Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)

no.8707/Mum./2011 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present cross appeal has been filed against the impugned final assessment order dated 28/10/2011 passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 ("the Act"), pursuant to the directions issued ... assessee having pages 1-15. The Addl. CIT, Range-2(3), Mumbai, passed the draft assessment order on 24/12/2010 and impugned final assessment order on 28/10/2011. 5. The learned Sr. Counsel by referring to the provisions of section 143(2) as well as section 143(3) of the Act submitted

Ishares India 50 Etf (As A Successor to Ishares India Mauritius Co (Liquidated)), Mumbai vs. DCIT (International Tax)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4602/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Ishares Core Emerging Mauritius Co, Mumbai vs. DCIT (International Tax)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4601/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Ishares Emerging Markets Minimum Volatility Mauritius Co, Mumbai vs. DCIT (International Tax)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4600/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Ishares Msci Emerging Markets Etf (As A Successor to Ishares Emerging Markets Index Mauritius Co (Liquidated)), Mumbai vs. DCIT (International Tax)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4598/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Ishares Msci Emerging Markets Asia Etf (As A Successor to Ishares Em Asia Mauritius Co (Liquidated)), Mumbai vs. DCIT (International Taxation)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4597/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Ishares Msci All Country Asia Ex Japan Etf (As A Successor to Ishares All Country Asia Ex Japan Mauritius Co (Liquidated)), Mumbai vs. DCIT (International Taxation)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4596/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Ishares India Index Mauritius Company, Mumbai vs. DCIT (International Taxation)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4595/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Ishares India SC Mauritius Company, Mumbai vs. DCIT (International Taxation)-2(2)(2), Mumbai

In the result, the appeals of the assessees in ITA

ITA 4593/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Jun 2024AY 2021-22

Bench: Smt Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

Section 143(3)

ITA.No.4593, 4595, 4596, 4597, 4598, 4600, 4601 & 4602 /Mum/2023 is with regard to arithmetic error in the computation sheet annexed to the final assessment order. The ld. AR submitted that there are certain arithmetical errors in the computation sheet and that the assessee has filed a petition under section

Daeseung Autoparts India Private Limited, Kancheepuram vs. ACIT (OSD), Chennai

The appeal stand partly allowed in terms of our above order

ITA 752/CHNY/2017[2012-13]Status: DisposedITAT Chennai04 Jun 2024AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.752/Chny/2017 (िनधा;रणवष; / Assessment Year: 2012-13) M/S. Daeseung Autoparts India Pvt. Ltd. Acit (Osd) Plot No,474, Mannur Village, Corporate Range-1, बनाम/ Vs. Valarpuram Post, Sriperumpudhur Taluk Chennai. Kanchipuram- 602 105. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccd-5629-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Vikram Vijayaraghavan (Advocate)- Ld. Ar " थ"कीओरसे/Respondent By : Shri G. Suresh (Jcit)- Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 28-05-2024 घोषणा की तारीख /Date Of Pronouncement : 04-06-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Vikram Vijayaraghavan (Advocate)- Ld. ARFor Respondent: Shri G. Suresh (JCIT)- Ld. Sr. DR
Section 143(3)Section 144C(5)Section 154Section 92C

Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2012-13 arises out of final assessment order dated 19.01.2017 passed by Ld. Assessing Officer, (AO) u/s 143(3) r.w.s. 144C(13) r.w.s. 92CA pursuant to the directions of Ld. Dispute Resolution Panel-2, Bengaluru ... assessment order was passed on 15.03.2016 which was subjected to assessee’s objections before Ld. DRP. Pursuant to the directions of Ld. DRP, final assessment order was passed against which the assessee is in further appeal before us. The grounds of appeal read as under: - 1. The order passed

Embassy One Developers Private Limited, Bangalore, India vs. The Deputy Commissioner of Income Tax, Circle 2(1)(1), Bangalore, India

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

ITA 312/BANG/2024[AY 2009-10]Status: DisposedITAT Bangalore04 Jun 2024

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri D.K. Mishra, D.R
Section 143(3)Section 92C(3)

order dated vide its directions dated 08.12.2023, granted partial relief to the Assessee. Pursuant to the DRP directions, the Assessing Officer passed a final assessment order dated 27.12.2023, in which the aggregate TP adjustment was reworked to Rs. 4,38,75,001/-. Aggrieved by the final assessment order, the Assessee ... provide adequate risk adjustment during benchmarking analysis. IT(TP)A No.312/Bang/2024 Embassy One Developers Private Limited, Bangalore Page 7 of 10 C. FINAL ASSESSMENT ORDER: Pursuant to the directions of the DRP, the AO passed a final assessment order, wherein the TP adjustment stood reduced

Johnson & Johnson Pte Ltd, Mumbai vs. Commissioner of Income Tax (Appeals)-57 Income Tax Departmetnt, Mumbai

ITA 364/MUM/2024[2018-19]Status: DisposedITAT Mumbai04 Jun 2024AY 2018-19

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Rajan VoraFor Respondent: Shri Anil Sant
Section 143(3)Section 144C(3)Section 250Section 253

learned Commissioner of Income Tax (Appeals)-57, Mumbai, [“learned CIT(A)”], for the assessment year 2018-19, which in turn arose from the final assessment order dated 07/09/2021 passed under section 143(3) r/w section 144C(3) of the Act. The sole ground raised by the assessee, in the present

Hapag-Llyod Aktiengesellschaft, Mumbai vs. DCIT-International Taxation-2(2)(2), Mumbai

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

ITA 4535/MUM/2023[2021-22]Status: DisposedITAT Mumbai04 Jun 2024AY 2021-22

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Niranjan GovindekarFor Respondent: Shri Anil Sant
Section 143(3)Section 144C(13)Section 144C(5)Section 44B

04/06/2024 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been filed by the assessee challenging the impugned final assessment order dated 16/10/2023, passed under section 143(3) r/w section 144C(13) of the Income Tax Act, 1961 ("the Act"), pursuant to the directions issued ... largely the same as in the preceding years. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order taxing the freight earned from feeder to feeder vessels and freight earned from the entire journey of feeder vessels amounting to Rs.38

Van Oord Dredging and Marine Contractors Bv, Mumbai vs. Assistant Commissioner of Income Tax, Intl. Tax Circle - 4(3)(1), Mumbai

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

ITA 4533/MUM/2023[2021-22]Status: DisposedITAT Mumbai04 Jun 2024AY 2021-22

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Darshan KoikarFor Respondent: Shri Anil Sant
Section 143(3)Section 144C(13)Section 144C(5)Section 244ASection 270A

07/05/2024 Date of Order – 04/06/2024 ORDER PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been filed by the assessee challenging the impugned final assessment order dated 17/10/2023, passed under section 143(3) r/w section 144C(13) of the Income Tax Act, 1961 ("the Act"), pursuant to the directions issued ... occasion to decide the issue under consideration. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order treating the Management Service Fees as 'Royalty' taxable at the rate of 10%. Being aggrieved, the assessee is in appeal before us. 8. During

Mckinsey Knowledge Centre India Pvt. Ltd., Haryana vs. DCIT Circle 16(1), Delhi

In the result, assessee’s appeal is partly allowed for statistical purposes

ITA 475/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Jun 2024AY 2017-18

Bench: Shri Shamim Yahya & Shri Sudhir Kumarmckinsey Knowledge Centre India Pvt. Ltd., Vs. Dcit, Circle 16 (1), 3Rd Floor, Block Iii, Delhi. Vatika Business Park, Sector 49, Sohna Road, Gurgaon – 122 018 (Haryana). (Pan : Aaccm2356G) (Appellant) (Respondent) Assessee By : Shri Porus Kaka, Sr. Advocate Shri Divesh Chawla, Advocate Revenue By : Shri Rajesh Kumar, Cit Dr Date Of Hearing : 24.04.2024 Date Of Order : 04.06.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Assessing Officer Dated 21.01.2022 Pursuant To The Directions Issued By The Drp For The Assessment Year 2017-18. 2. Grounds Of Appeal Taken By The Assessee Read As Under :-

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR

case, the learned AO has erred in levying consequential interest under Section 234B of the Act in the income tax computation as per final assessment order. 18. On the facts and in circumstances of the case, the learned AO has erred in considering an incorrect amount of book profits

Syed Gulam Mohiuddin, Hyderabad vs. ITO, International Taxation-1, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 136/HYD/2023[2017-18]Status: DisposedITAT Hyderabad03 Jun 2024AY 2017-18

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita No.136/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Syed Gulam Vs. Income Tax Officer Mohiuddin (International Taxation)-1 Hyderabad Hyderabad Pan:Decpm0365H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Assessment Order Dated 12.01.2023 Of The Learned Assessing Officer (International Taxation-1), Hyderabad, Relating To A.Y.2017-18. 2. The Grounds Raised By The Assessee Read As Under: “1. The Final Assessment Order Passed By The Income Tax Officer (Int Taxn)-1,Hyd (Herein After Referred To As 'Ao) Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant.

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shiva Sewak, CIT(DR)
Section 147Section 148Section 148(2)Section 151Section 69

learned Assessing Officer (International Taxation-1), Hyderabad, relating to A.Y.2017-18. 2. The grounds raised by the assessee read as under: “1. The Final assessment order passed by the Income Tax Officer (Int Taxn)-1,HYD (herein after referred to as 'AO) is erroneous both on facts ... additions made by the Assessing Officer towards cash payment for purchase of property as unexplained investment. Thereafter, the Assessing Officer has passed final assessment order u/s 144 r.w.s. 144C(13) of the Act on 12.01.2023 and determined the total income at Rs.22.00 lakhs. 4. Aggrieved by the final assessment order

M/S Kantar Gdc India Pvt. Ltd. (Formerly Tns India Pvt Ltd), Hyderabad vs. Dy. Commissioner of Income Tax, Circle-2(2), Hyderabad

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

ITA 2261/HYD/2017[2013-14]Status: HeardITAT Hyderabad03 Jun 2024AY 2013-14

Bench: Shri Mahavir Singh & Shri Manjunatha, G.आ.अपी.सं /Ita No.2261/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2013-14) M/S. Kantar Gdc India (P) Vs. Dy. C. I. T. Ltd (Formerly Tns India (P) Circle 2(2) Ltd, Hyderabad Hyderabad Pan:Aabcn2278F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Harpreet Singh Ajmani राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order

For Appellant: Advocate Harpreet Singh AjmaniFor Respondent: : Shri Shiva Sewak, CIT(DR)
Section 143(3)Section 144C(5)Section 271(1)(c)

hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/ORDER Per Manjunatha, G. A.M This appeal filed by the assessee is directed against the final assessment order passed by the Assessing Officer u/s 143(3) r.w.s. 144(5) r.w.s. 144(13) of the I.T. Act, 1961 in pursuant to Dispute Resolution ... furnish the relevant documents before the Assessing Officer and thereby failed to discharge its onus. Thereafter, the Assessing Officer has passed the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act on 30.10.2017 and determined the total income of Page

Pfizer Healthcare India Private Limited, Chennai vs. ACIT, Circle-1-Ltu, Chennai

In the result, the corporate additions made in the assessment order would not survive

ITA 641/CHNY/2023[2016-17]Status: DisposedITAT Chennai03 Jun 2024AY 2016-17

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.641/Chny/2023 (िनधा9रण वष9 / Assessment Year: 2016-17) M/S.Pfizer Healthcare India Pvt. Limited Dcit (Formerly Known As Hospira Healthcare India Corporate Circle-5(2)-Ltu, बनाम/ Private Limited) Chennai. Vs. 237, Emerald Building, Anna Salai, Chennai-600 006. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabco-2190-F (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri Ashik Shah (Ca)-Ld. Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 09-05-2024 घोषणा की तारीख /Date Of Pronouncement : 03-06-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Ashik Shah (CA)-Ld. ARFor Respondent: Shri Nilay Baran Som (CIT)-Ld. DR
Section 143(3)Section 144CSection 144C(15)(b)Section 14ASection 153(1)Section 153(4)Section 2(24)Section 31Section 35Section 92C

01/11/2019 the Appellant Date of issuance of Draft Assessment Order in the case 31/12/2019 of the Appellant 28/02/2020 Date of issuance of Final Assessment Order in the case of the Appellant Since the transfer pricing proceedings were barred by limitation of time, the order dated November 01, 2019 is void ... read with Section 153(4) of the Act, i.e., on or before December 31, 2019. However, since the assessment was concluded vide the final assessment order dated February 28, 2020, the impugned assessment is clearly barred by statutory limitation. Accordingly, the impugned assessment for the subject year is null

Jet Air Agencies Pvt Ltd, West Bengal vs. Central Circle 2(3)Ahmedabad, Ahmedabad

In the result, Ground Nos

ITA 685/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad31 May 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Ram Awatar Dhoot, A.RFor Respondent: Shri Santosh Kumar, Sr. DR
Section 147Section 234BSection 271(1)

provided to M/s. Affluence Commodities for which the assessee has earned unaccounted commission income amounting to Rs. 90,00,000/-. However, in the final assessment order, no addition on this count was made by the Assessing Officer. Accordingly, the reopening of assessment in the case of the assessee ... that his company had provided bogus accommodation entries to beneficiaries in lieu of which the assessee had received additional commission income. In the final assessment order additions were also made in respect of bogus loss accommodation entries provided to these entities. Further, in the reasons for reopening