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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

Jet Air Agencies Pvt. Ltd, West Bengal vs. The ACIT, Centra Circle-2(3), Ahmedabad

In the result, Ground Nos

ITA 1597/AHD/2019[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

Jet Air Agencies Pvt. Ltd, West Bengal vs. The ACIT, Centra Circle-2(3), Ahmedabad

In the result, Ground Nos

ITA 1596/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

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

Jet Air Agencies Pvt. Ltd, West Bengal vs. The ACIT, Centra Circle-2(3), Ahmedabad

In the result, Ground Nos

ITA 1595/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 May 2024AY 2011-12

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

Jet Air Agencies Pvt. Ltd, West Bengal vs. The ACIT, Centra Circle-2(3), Ahmedabad

In the result, Ground Nos

ITA 1594/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad31 May 2024AY 2010-11

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

Satyam Venture Engineering Services Private Limited, Secunderabad vs. Assistant Commissioner of Income Tax, Central Circle -3(2), Hyderabad

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

ITA 192/HYD/2021[2016-17]Status: DisposedITAT Hyderabad31 May 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita-Tp No. 192/Hyd/2021 (धििाारण वर्ा / Assessment Year: 2016-17) Satyam Venture Assistant Commissioner Engineering Services Vs. Of Income Tax, Private Limited, Central Circle-3(2), Secunderabad Hyderabad [Pan No. Aafcs3287D] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

For Appellant: Shri E.V. Sri Krishna, ARFor Respondent: Ms. L. Sunitha Rao, CIT-DR
Section 143(3)Section 40

सुिवाई की तारीख/Date of hearing: 07/05/2024 घोर्णा की तारीख/Pronouncement on: 31/05/2024 आदेश / ORDER PER K. NARASIMHA CHARY, J.M: Aggrieved by the final assessment order dated 17/03/2021 passed consequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru (“DRP”), in the case of M/s. Satyam Venture Engineering Services

Isoft Health Management India Private Limited, Chennai vs. DCIT, Chennai

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

ITA 976/CHNY/2015[2010-11]Status: DisposedITAT Chennai31 May 2024AY 2010-11

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.976/Chny/2015 िनधा"रण वष"/Assessment Year: 2010-11 M/S. Isoft Health Management India Vs The Deputy Commissioner Of Private Limited, 4Th Floor, Capital . Income Tax, Towers, No. 180, Kodambakkam High Corporate Circle 2(2), Road, Nungambakkam, Chennai 600 034. Chennai 600 034. [Pan: Aalcs8600A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Vikram Vijayaragahavan, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 15.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.05.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 23.02.2015 Passed By The Assessing Officer Under Section 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Vikram Vijayaragahavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)

Pronouncement : 31.05.2024 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal by the assessee is directed against the final assessment order dated 23.02.2015 passed by the Assessing Officer under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 [“Act” in short

Maya Kapoor, Gurgaon vs. Income Tax Officer, Ward-2(4), Gurgaon

The appeal of the assessee is allowed

ITA 783/DEL/2024[2021-22]Status: DisposedITAT Delhi31 May 2024AY 2021-22

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Rakesh Gupta, Adv. and Shri Deepesh Garg, AdvFor Respondent: Shri Om Parkash, Sr. Dr
Section 139Section 143(1)Section 154Section 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 Page 4 of 12 ITA No.-783/Del/2024 Maya Kapoor. terms of the Rule 128 is only directory in nature

Veeratham Sachdev, New Delhi vs. DCIT Circle International Taxation, New Delhiq

In the result, both the appeal of the assessee are allowed for

ITA 390/DEL/2023[2016-17]Status: DisposedITAT Delhi31 May 2024AY 2016-17

Bench: Dr. Brr Kumar & Shri Sudhir Pareek

For Appellant: Shri Harshit Chauhan, AdvFor Respondent: Shri Vijay B Vasanta, CIT- DR

reply was received from SBI Mutual Fund and BNP Paribas Mutual Fund. For the sake of ready reference, the relevant part of the final assessment order is reproduced herein below:- “9(ii) Further, no reply was received from SBI Mutual Fund and BNP Paribas Mutual Fund with respect

Veeratham Sachdev, New Delhi vs. DCIT Circle International Taxation, New Delhi

In the result, both the appeal of the assessee are allowed for

ITA 374/DEL/2023[2013-14]Status: DisposedITAT Delhi31 May 2024AY 2013-14

Bench: Dr. Brr Kumar & Shri Sudhir Pareek

For Appellant: Shri Harshit Chauhan, AdvFor Respondent: Shri Vijay B Vasanta, CIT- DR

reply was received from SBI Mutual Fund and BNP Paribas Mutual Fund. For the sake of ready reference, the relevant part of the final assessment order is reproduced herein below:- “9(ii) Further, no reply was received from SBI Mutual Fund and BNP Paribas Mutual Fund with respect

Millenium Vinimay Pvt. Ltd., Delhi vs. ACIT, CC-28, New Delhi

In the result, appeal of the assessee is allowed

ITA 458/DEL/2022[2015-16]Status: DisposedITAT Delhi31 May 2024AY 2015-16

Bench: Mr. S. Rifaur Rahman & Ms. Madhumita Royi.T.A. No. 458 /Del/2022 (Assessment Year : 2015-16) Millenium Vinimay Pvt. Vs. Acit Ltd., Dpt, 801, Dlf Central Circle – 28 Prime Tower, Plot No.F- New Delhi 79 & 80, Okhla Industrial Area, Phase-1, New Delhi Pan: Aaecm 5383 R (Appellant) .. (Respondent) & I.T.A. No. 827/Del/2022 (Assessment Year : 2015-16) Dcit Vs. Millenium Vinimay Pvt. Ltd., Central Circle -28 164, M.G. Road, Budge, Delhi West Bengal – 700 137 Pan: Aaecm 5383 R (Appellant) .. (Respondent)

For Appellant: Shri Gautam Jain, AdvFor Respondent: Shri Anshul, Sr. D.R
Section 132(4)Section 132ASection 139Section 143(1)Section 153ASection 153CSection 153C(1)Section 153DSection 250(6)

Veena Singh AXJPS9588H 2017-18 1165,510/- 2,52,33,8201- 3. Copies of the final assessment orders should be forwarded to ITA Nos.458 & 827/Del/2022 Millenium Vinimay Pvt. Ltd. Asst.Year : 2015-16 this office immediately after passing the orders. Proposal -tor retention of seized- material, should also be forwarded

Zydus Lifesciences Limited (Formerly Known As Cadila Healthcare Ltd.), Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

order was also found to be invalid, having no legs to stand upon, in the absence of valid TPO’s order. Ultimately, the final assessment order was also quashed since barred by limitation as further held by the ITAT – Mumbai Benches in the above matter with the following observations ... eligible assessee u/s 144C(15) of the Act. In view of the same, the Ld. AO was ostensibly required to pass the final assessment order u/s 143(3) of the Act on that day. Having said that, the draft assessment order passed by the Ld. AO under the provisions

Uttam Energy Limited, Pune vs. ACIT Circle-12, Pune

Appeal of the Assessee is partly allowed

ITA 2033/PUN/2019[2015-16]Status: DisposedITAT Pune30 May 2024AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 153Section 153(1)Section 40A(2)(b)Section 92BSection 92C

16/05/2024 Date of pronouncement 30/05/2024 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: This appeal has been filed by the assessee against the final assessment order of the learned ACIT, Circle-12, Pune passed u/sec. 143(3) r.w.s. 144C(13) of the of the Income Tax Act, 1961 (in short ... Ld.AR submitted the additional ground of appeal as under : “1. The learned Assessing Officer erred on facts and in law in passing the final assessment order beyond the time limits prescribed for the same u/s 153(1) r.w.s 153(4) OF THE Act thereby making the said order invalid

Gartner Ireland Limited, Mumbai vs. Deputy Comm. of Income Tax-2(3)(2), Mumbai

In the result, the appeal filed by the assessee is partly allo

ITA 2460/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 May 2024AY 2019-20

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2019-2020 Gartner Ireland Ltd., Dcit-2(3)(2), 3Rd Floor, Two Park Place, 17Th Floor, 1711, Air India Hatch Street, Dublin 2, Vs. Building, Nariman Point, Ireland D02 Np94. Mumbai-400021. Pan No. Aaccg 2919 B Appellant Respondent Assessee By : Mr. Farooq Irani Revenue By : Mr. A.K. Ambastha, Sr. Dr : Date Of Hearing 12/04/2024 : Date Of Pronouncement 30/05/2024

For Appellant: Mr. Farooq IraniFor Respondent: Mr. A.K. Ambastha, Sr. DR
Section 234DSection 9(1)(vi)

Date of Hearing 12/04/2024 : Date of pronouncement 30/05/2024 ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against final assessment order dated 27.07.2022 , which has been passed by the Ld. Assistant Commissioner of Income-tax-International Taxation Circle 2(3)(2), Mumbai (in short ‘the Assessing ... Officer. Pursuant to the directions of the L of the Ld. DRP, the Assessing Officer has passed the Assessing Officer has passed impugned final assessment order on 27.07.2022 making the impugned final assessment order on 27.07.2022 making the impugned final assessment order on 27.07.2022 making the addition of subscription fees

Dilip Kapur, United States of America vs. ACIT, Circle 2(1)(2) International Taxation, New Delhi

Appeal of the assessee is allowed

ITA 2059/DEL/2023[2020-21]Status: DisposedITAT Delhi30 May 2024AY 2020-21

Bench: Dr. Brr Kumarshri Sudhir Pareek

For Appellant: Shri Ved Jain, Adv. and Shri Aman Garg, CAFor Respondent: Shri Vijay B Vasanta, CIT- DR
Section 142ASection 143(3)Section 144CSection 234D

pertaining to Assessment Year 2020-21, on the following grounds of appeal: “1. On the facts and circumstances of the case, the final assessment order passed by the learned Assistant Commissioner of Income Tax, Circle International Taxation, 2(1)(2) (hereinafter referred to as 'Assessing Officer') under Section

Navin Kumar Jain, Indore vs. ITO ACIT Dycit Faceless Assessment, Indore

In the result, both appeals of the assessee are allowed

ITA 469/IND/2023[2014-15]Status: DisposedITAT Indore29 May 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 148

including show cause notice along with draft assessment order and filed the written submission as well as affidavit. The AO has framed final assessment order dated 22.03.2022 and made addition of Rs.50,17,236/- in para 3 to 6 as under: “3. Therefore, in view of the above

Navin Kumar Jain, Indore vs. Income Tax Officer Faceless Assessment Centre, Indore

In the result, both appeals of the assessee are allowed

ITA 468/IND/2023[2013-14]Status: DisposedITAT Indore29 May 2024AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 148

including show cause notice along with draft assessment order and filed the written submission as well as affidavit. The AO has framed final assessment order dated 22.03.2022 and made addition of Rs.50,17,236/- in para 3 to 6 as under: “3. Therefore, in view of the above

M/S. Bengal Tiger Line Pte Ltd, Singapore vs. DCIT, Intl Tax 1(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 1419/CHNY/2023[2018-19]Status: DisposedITAT Chennai29 May 2024AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Ragunatha, Hon’Bleआयकर अपील सं./Ita No.: 1419/Chny/2023 िनधा"रण वष" / Assessment Year: 2018-19 M/S. Bengal Tiger Line Pte Ltd., Deputy Commissioner Of 200, Cantonment Road, V. Income Tax, 13 01, South Point, International Taxation -1(1), Singapore. No. 16, Greams Road, [Pan: Aadcb-6864-F] Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. S.P. Chidambaram, Advocate अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 16.04.2024 घोषणा क" तारीख/Date Of Pronouncement : 29.05.2024

For Respondent: Shri. D. Hema Bhupal, JCIT
Section 133Section 143(2)Section 144C(5)Section 147Section 148Section 148ASection 44B

RAGHUNATHA, ACCOUNTANT MEMBER: Aforesaid appeal by assessee for assessment year 2018- 19 arising out of final assessment order passed by the ld. Assessing Officer (AO) u/s. 147 r.w.s. 144C(13) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) on 09.11.2023 pursuant to the directions ... Rs.7,50,96,532/- assessed to tax in India u/s. 44B of the Act based on the directions of DRP and the consequential final assessment order is erroneous. 3. The brief facts of the case are that, the assessee is a shipping company incorporated in Singapore. The assessee has claimed

India Acorn Fund Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(1), Mumbai

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

ITA 4556/MUM/2023[2021-22]Status: DisposedITAT Mumbai29 May 2024AY 2021-22

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

For Appellant: Shri MADHUR Agarwal / FenilFor Respondent: Shri Anil Sant, Addl. CIT-DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 234ASection 234C

within the time limit prescribed under section 153 of the Act which is the outer time limit for passing the final assessment order and hence, the impugned order dated 16 October 2023 which is passed after 31 December 2022 (time limit as per Section 153 of the Act) is time

Brett Lee, Australia vs. ACIT, Circle Int. Taxation 2(2)(1), New Delhi

Appeal is allowed as indicated above

ITA 867/DEL/2023[2013-14]Status: DisposedITAT Delhi29 May 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singhassessment Year: 2013-14

Section 115BSection 133(6)Section 142(1)Section 144Section 147Section 148Section 3

pronouncement 29.05.2024 O R D E R PER SAKTIJIT DEY, VP: The captioned appeal has been filed by the assessee assailing the final assessment order dated 27.01.2023 passed u/s 147 read with section 144 of the Income-tax Act, 1961 (the “Act”), pertaining to the assessment year ... were found to 4 be devoid of merit, hence rejected. In terms with the directions of learned DRP, the Assessing Officer passed the final assessment order retaining the addition proposed in the draft assessment order. 3.3 Before us, learned counsel for the assessee submitted that the notice

Takenaka India Pvt Ltd, Gurgaon vs. JCIT (OSD) Circle-25(1), Gurgaon

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

ITA 5581/DEL/2019[2012-13]Status: DisposedITAT Delhi29 May 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia[Assessment Year : 2012-13] M/S. Takenaka India Pvt.Ltd., Vs Cit (A)-44, First Floor, Tower-C, Vatika First New Delhi. India Place, Mehrauli Gurgaon Road, Gurgaon, Haryana-122002. Pan-Aadct6143P Appellant Respondent Appellant By Shri Ashutosh Mohan Rastogi & Shri Dhruv Seth, Adv. Respondent By Shri Gaurav Bansal, Sr. Dr Date Of Hearing 15.04.2024 Date Of Pronouncement 29.05.2024 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By Commissioner Of Income Tax (Appeals) (“Cit(A)”)-44, New Delhi Dated 24.04.2019 For The Assessment Year 2012-13. 2. The Assessee Has Assailed The Correctness Of The Order On Following Grounds:-

Section 143(2)Section 143(3)Section 250(6)Section 271(1)(c)Section 92CSection 92C(3)Section 92D

file any objections before Ld. Dispute Resolution Panel (“DRP”) as intimated to AO vide letter dated 10.05.2016. Therefore, the AO proceeded to frame final assessment order u/s 143(3) r.w.s. 144C(3) of the Act. Thereby, after making adjustment suggested by the TPO, the AO assessed the income