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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

Vodafone India Limited, Mumbai vs. Assistant Commissioner of Income Tax-8(3)(2), Mumbai

ITA 2834/MUM/2017[2012-13]Status: DisposedITAT Mumbai17 May 2024AY 2012-13
For Appellant: Shri P.J. PardiwalaFor Respondent: Shri T. Sankar
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

Year 2011-12 2. We would first take up take up cross appeals for the Assessment Year 2011-12 which are directed against Final Assessment Order dated, 28/01/2016, passed under Section 144C(13) read with Section 143(3) of the Income Tax Act, 1961 [hereinafter referred ... disposed off the objections granting partial relief to the Assessee. As per the directions of the DRP, the Assessing Officer passed the Final Assessment Order, dated 28/01/2016, under Section 143(3) read with Section 144C(13) of the Act, assessing total income of the Assessee

Vodafone India Ltd, Mumbai vs. Asst CIT 8(3)(2), Mumbai

ITA 884/MUM/2016[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

Year 2011-12 2. We would first take up take up cross appeals for the Assessment Year 2011-12 which are directed against Final Assessment Order dated, 28/01/2016, passed under Section 144C(13) read with Section 143(3) of the Income Tax Act, 1961 [hereinafter referred ... disposed off the objections granting partial relief to the Assessee. As per the directions of the DRP, the Assessing Officer passed the Final Assessment Order, dated 28/01/2016, under Section 143(3) read with Section 144C(13) of the Act, assessing total income of the Assessee

DCIT 8(3)(2), Mumbai vs. M/S Vodafone Idea Limited (Earlier Known As Vodafone India Limited Which Now Stands Merged With Idea Cellular Limited (Icl) and Consequently Known As Vodafone Idea Limited), Mumbai

ITA 1919/MUM/2016[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12
For Appellant: Shri P.J. PardiwalaFor Respondent: Shri T. Sankar
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

Year 2011-12 2. We would first take up take up cross appeals for the Assessment Year 2011-12 which are directed against Final Assessment Order dated, 28/01/2016, passed under Section 144C(13) read with Section 143(3) of the Income Tax Act, 1961 [hereinafter referred ... disposed off the objections granting partial relief to the Assessee. As per the directions of the DRP, the Assessing Officer passed the Final Assessment Order, dated 28/01/2016, under Section 143(3) read with Section 144C(13) of the Act, assessing total income of the Assessee

Salesforce.Com Singapore Pte Ltd, Singapore vs. Assistant Commissioner of Income-Tax, International Taxation Circle-3(1)(2), Delhi, New Delhi

Appeal is partly allowed

ITA 3347/DEL/2023[2021-22]Status: DisposedITAT Delhi17 May 2024AY 2021-22

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh: A.Y. 2018-19 : A.Y. 2019-20 : A.Y. 2020-21

Section 143(3)Section 144C(13)Section 9(1)(vii)

Date of pronouncement 17.05.2024 O R D E R PER SAKTIJIT DEY, VP: Captioned appeals, by the same assessee, arise out of final assessment orders passed u/s 143(3) read with Section 144C(13) of the Income-tax Act, 1961, 2 ITA nos. 1923, 1924/Del/2022; & 1789 & 3347/Del/2023 pertaining to assessment ... from CRM services and Rs. 2,69,11,689/- towards interest from income-tax refund, however, while computing assessee’s income in the final assessment order the Assessing Officer has erroneously included the interest on income tax refund in the receipts of CRM services. 4.2 On a query from

Telstra Singapore Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, Circle (3)(1)(1), International Taxation, New Delhi, India

In the result, the appeal is partly allowed

ITA 3318/DEL/2023[2021-22]Status: DisposedITAT Delhi17 May 2024AY 2021-22

Bench: Shri Saktijit Dey, Vice- & Shri Brajesh Kumar Singhassessment Year: 2021-22

Section 143(3)Section 144C(13)Section 9(1)(vi)

Date of hearing 14.05.2024 Date of pronouncement 17.05.2024 ORDER PER SAKTIJIT DEY, VICE-PRESIDENT By filing this appeal, the assessee has assailed the final assessment order dated 28.09.2023 passed under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 (in short ... deducted on the interest on income tax refund has not been granted by the Assessing Officer, while computing the tax liability in the final assessment order. Keeping in view the aforesaid submissions of the assessee, we direct the Assessing Officer to factually verify assessee’s claim and grant TDS credit

Saleforce.Com Singapore Pte Ltd, Singapore vs. ACIT, Circle-3(1)(2) Int, Taxation, New Delhi

Appeal is partly allowed

ITA 1789/DEL/2023[2020-21]Status: DisposedITAT Delhi17 May 2024AY 2020-21

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh: A.Y. 2018-19 : A.Y. 2019-20 : A.Y. 2020-21

Section 143(3)Section 144C(13)Section 9(1)(vii)

Date of pronouncement 17.05.2024 O R D E R PER SAKTIJIT DEY, VP: Captioned appeals, by the same assessee, arise out of final assessment orders passed u/s 143(3) read with Section 144C(13) of the Income-tax Act, 1961, 2 ITA nos. 1923, 1924/Del/2022; & 1789 & 3347/Del/2023 pertaining to assessment ... from CRM services and Rs. 2,69,11,689/- towards interest from income-tax refund, however, while computing assessee’s income in the final assessment order the Assessing Officer has erroneously included the interest on income tax refund in the receipts of CRM services. 4.2 On a query from

Selesforce.Com Singapure Pte Ltd., Singapure vs. ACIT International Taxation, Circle-3(1)(2), New Delhi

Appeal is partly allowed

ITA 1924/DEL/2022[2019-20]Status: DisposedITAT Delhi17 May 2024AY 2019-20

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh: A.Y. 2018-19 : A.Y. 2019-20 : A.Y. 2020-21

Section 143(3)Section 144C(13)Section 9(1)(vii)

Date of pronouncement 17.05.2024 O R D E R PER SAKTIJIT DEY, VP: Captioned appeals, by the same assessee, arise out of final assessment orders passed u/s 143(3) read with Section 144C(13) of the Income-tax Act, 1961, 2 ITA nos. 1923, 1924/Del/2022; & 1789 & 3347/Del/2023 pertaining to assessment ... from CRM services and Rs. 2,69,11,689/- towards interest from income-tax refund, however, while computing assessee’s income in the final assessment order the Assessing Officer has erroneously included the interest on income tax refund in the receipts of CRM services. 4.2 On a query from

Salesforce.Com Singapore Pte Ltd, Karnataka vs. ACIT, Circle-3(1)(2), International Taxation, New Delhi

Appeal is partly allowed

ITA 1923/DEL/2022[2018-19]Status: DisposedITAT Delhi17 May 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri Brajesh Kumar Singh: A.Y. 2018-19 : A.Y. 2019-20 : A.Y. 2020-21

Section 143(3)Section 144C(13)Section 9(1)(vii)

Date of pronouncement 17.05.2024 O R D E R PER SAKTIJIT DEY, VP: Captioned appeals, by the same assessee, arise out of final assessment orders passed u/s 143(3) read with Section 144C(13) of the Income-tax Act, 1961, 2 ITA nos. 1923, 1924/Del/2022; & 1789 & 3347/Del/2023 pertaining to assessment ... from CRM services and Rs. 2,69,11,689/- towards interest from income-tax refund, however, while computing assessee’s income in the final assessment order the Assessing Officer has erroneously included the interest on income tax refund in the receipts of CRM services. 4.2 On a query from

Primetals Technologies India Pvt. Ltd., Kolkata vs. ACIT, Circle - 1(1), Kolkata

In the result, appeals of the assessee for Assessment Year 2017-18

ITA 372/KOL/2022[2018-2019]Status: DisposedITAT Kolkata16 May 2024AY 2018-2019

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 371 & 372/Kol/2022 Assessment Year: 2017-18 & 2018-19 Primetals Technologies India Pvt. Ltd. Acit, Circle-1(1), Kolkata 5Th Floor, Tower-C Vs Dlf, It Park-I 08 Majore Arterial Road New Town Kolkata - 700156 [Pan : Aaecv9657M] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ajoy Vora, Sr. Advocate & Pooja Saraf, Ar Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 21/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 16/05/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Final Assessment Orders Framed U/S 143(3) R.W.S. 144C & 144C(5) Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) By The Deputy Commissioner Of Income Tax, Circle – 1(1), Kolkata (Hereinafter The “Ld. Ao”) Even Dt. 29/04/2022, Passed In Pursuance Of The Directions Of The Ld. Dispute Resolution Panel -2, New Delhi, Dt. 18/02/2022 For Assessment Year 2017-18 & Dt. 04/03/2022 For Assessment Year 2018-19, Passed U/S 144C(5) Of The Act. 2. The Assessee Has Raised The Following Grounds Of Appeal For Assessment Year 2017-18:- “Ground 1:

For Appellant: Shri Ajoy Vora, Sr. Advocate and Pooja Saraf, ARFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(3)Section 144CSection 144C(5)Section 156Section 32(1)Section 92C

MANISH BORAD, ACCOUNTANT MEMBER : The present appeals are directed at the instance of the assessee against the final assessment orders framed u/s 143(3) r.w.s. 144C & 144C(5) of the Income Tax Act, 1961 (hereinafter ‘the Act’) by the Deputy Commissioner of Income Tax, Circle – 1(1), Kolkata (hereinafter ... hereinafter referred to as ‘the Act’) and under section 92CA(3) read with section 144C(5) of the Act respectively, the final assessment order dated April 29, 2022 passed by the Learned Assessing Officer (hereinafter referred to as ‘Learned AO’ or ‘Ld. AO’) under section 143(3) read with section

Primetals Technologies India Private Limited, Kolkata vs. ACIT, Circle-1(1), Kolkata

In the result, appeals of the assessee for Assessment Year 2017-18

ITA 371/KOL/2022[2017-2018]Status: DisposedITAT Kolkata16 May 2024AY 2017-2018

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 371 & 372/Kol/2022 Assessment Year: 2017-18 & 2018-19 Primetals Technologies India Pvt. Ltd. Acit, Circle-1(1), Kolkata 5Th Floor, Tower-C Vs Dlf, It Park-I 08 Majore Arterial Road New Town Kolkata - 700156 [Pan : Aaecv9657M] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ajoy Vora, Sr. Advocate & Pooja Saraf, Ar Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 21/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 16/05/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Final Assessment Orders Framed U/S 143(3) R.W.S. 144C & 144C(5) Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) By The Deputy Commissioner Of Income Tax, Circle – 1(1), Kolkata (Hereinafter The “Ld. Ao”) Even Dt. 29/04/2022, Passed In Pursuance Of The Directions Of The Ld. Dispute Resolution Panel -2, New Delhi, Dt. 18/02/2022 For Assessment Year 2017-18 & Dt. 04/03/2022 For Assessment Year 2018-19, Passed U/S 144C(5) Of The Act. 2. The Assessee Has Raised The Following Grounds Of Appeal For Assessment Year 2017-18:- “Ground 1:

For Appellant: Shri Ajoy Vora, Sr. Advocate and Pooja Saraf, ARFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(3)Section 144CSection 144C(5)Section 156Section 32(1)Section 92C

MANISH BORAD, ACCOUNTANT MEMBER : The present appeals are directed at the instance of the assessee against the final assessment orders framed u/s 143(3) r.w.s. 144C & 144C(5) of the Income Tax Act, 1961 (hereinafter ‘the Act’) by the Deputy Commissioner of Income Tax, Circle – 1(1), Kolkata (hereinafter ... hereinafter referred to as ‘the Act’) and under section 92CA(3) read with section 144C(5) of the Act respectively, the final assessment order dated April 29, 2022 passed by the Learned Assessing Officer (hereinafter referred to as ‘Learned AO’ or ‘Ld. AO’) under section 143(3) read with section

Microchip Technology (India) Private Limited, Bengaluru vs. DCIT Circle 4(1)(1), Bmtc Building, Koramangala

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

ITA 817/BANG/2023[2018-19]Status: DisposedITAT Bangalore16 May 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2018-19

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri Biju M.K., CIT-DR
Section 143(2)Section 143(3)Section 25oSection 270ASection 37Section 92C

rendering such an order to be invalid and never to have been issued as per para 4 of the said order, resultantly the final assessment order dated 27 September 2021 passed by learned AO under section 143(3) r.w.s. 144B of the Act pursuant to invalid and non-est draft

Kennametal India Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Bangalore

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

ITA 506/BANG/2022[2017-18]Status: DisposedITAT Bangalore15 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 143(3)Section 92C

which, vide its directions dated 24.02.2022 granted partial relief to the Assessee. Pursuant to the DRP directions, the Assessing Officer passed a final assessment order dated 30.03.2022 in which the aggregate TP adjustment was reworked to Rs. 10,60,65,735/-. Aggrieved by the final assessment order, the Assessee ... Sphinx Precision Ltd. 23. United Drilling Tools Ltd. 24. Emkay Taps and Cutting Tools Ltd. 25. Groz Engineering Tools Pvt. Ltd. 4.5 FINAL ASSESSMENT ORDER: The AO passed the final assessment order in which the TP adjustment stood reworked

Accel India Venture Fund II L.P., Cayman Islands vs. ACIT Circle-1(1)(1) Intl. Taxation, New Delhi

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

ITA 2655/DEL/2023[2020-21]Status: DisposedITAT Delhi15 May 2024AY 2020-21

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2020-21 Accel India Ventures Fund Ii Vs. Acit (International Taxation), L.P. Cayman Islands, Circle-1(1)(1), Walkers, 190 Elgin Avenue, New Delhi George Town, Grand Cayman Ky1 -9001, George Town, Not Listed 999999 Pan :Abpfa4451K (Appellant) (Respondent) Assessee By Sh. T. Suryanarayana, Sr. Advocate Department By Sh. Vijay B. Vasanta, Cit(Dr)

Section 143(3)Section 144C(13)

Date of hearing 06.05.2024 Date of pronouncement 15.05.2024 ORDER PER SAKTIJIT DEY, VICE-PRESIDENT Captioned appeal by the assessee arises out of the final assessment order dated 27.07.2023 passed under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 (in short ‘the Act’) pertaining ... assessee raised objections before learned DRP. Learned DRP disposed of the objections issuing certain directions to the Assessing Officer. However, in the final assessment order, the Assessing Officer repeated the additions made in the draft assessment order. 7. Before us, learned counsel appearing for the assessee submitted that, though

Bnp Paribas, Mumbai vs. Assistant Commissioner of Income Tax(Internationa Taxation)-Circle 1(3)(1), Mumbai

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

ITA 3416/MUM/2023[2020-21]Status: DisposedITAT Mumbai13 May 2024AY 2020-21

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopal

For Respondent: Ajay Kumar Sharma
Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 270A

Hearing 12.03.2024 Date of Pronouncement 13.05.2024 SHeI/ORDER Per Amarjit Singh (AM): The present appeal filed by the assessee is directed against the final assessment order dated 21.07.2023 passed u/s 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 pursuant to the direction issued by the ld. Dispute Resolution ... vide its order dated 27.06.2023 has dismissed the objection raised by the assessee and_ thereafter assessing officer has passed final assessment order on 21.07.2023 and assessed the total income at Rs.600,17,43,550/-. Further facts of the case are discussed while adjudicating the ground of appeal filed

Marsh India Insurance Brokers Private Limited, Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO/NFAC, Delhi

In the result, both the appeal

ITA 642/MUM/2022[2017-18]Status: DisposedITAT Mumbai13 May 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 & Assessment Year: 2017-18 Marsh India Insurance Brokers Additional/Joint/Deputy/Assistant Private Limited, Commissioner Of Income 1201-02, Tower, One India Vs. Tax/Income-Tax Officer, National Bulls Centre, Jupiter Mills E-Assessment Centre, Delhi. Compound, Senapati Bapat Marg, Elphinstone Road (West), Mumbai-400013. Pan No. Aadcm 4220 G Appellant Respondent Assessee By : Mr. Madhur Agrawal Revenue By : Mr. Manoj Kumar, Cit-Dr

For Appellant: Mr. Madhur AgrawalFor Respondent: Mr. Manoj Kumar, CIT-DR
Section 234ASection 234B

Hearing : 08/05/2024 : 13/05/2024 Date of pronouncement ORDER PER OM PRAKASH KANT, AM These two appeals by the assessee are directed against two separate final assessment orders dated 03.04.2021 and 09.02.2022, passed by the Ld. Assessing Officer, National E- Marsh India Insurance Brokers Pvt. Ltd. Marsh India Insurance Brokers ... case, the assessee filed an add In the case, the assessee filed an additional ground challenging the limitation in passing the final assessment order challenging the limitation in passing the final assessment order challenging the limitation in passing the final assessment order following the decision of the Hon’ble Bombay

Marsh India Insurance Brokers Pvt. Ltd, Mumbai vs. Addl /Jtdy/ACIT/ITO/NFAC, Mumbai

In the result, both the appeal

ITA 2471/MUM/2021[2016-17]Status: DisposedITAT Mumbai13 May 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 & Assessment Year: 2017-18 Marsh India Insurance Brokers Additional/Joint/Deputy/Assistant Private Limited, Commissioner Of Income 1201-02, Tower, One India Vs. Tax/Income-Tax Officer, National Bulls Centre, Jupiter Mills E-Assessment Centre, Delhi. Compound, Senapati Bapat Marg, Elphinstone Road (West), Mumbai-400013. Pan No. Aadcm 4220 G Appellant Respondent Assessee By : Mr. Madhur Agrawal Revenue By : Mr. Manoj Kumar, Cit-Dr

For Appellant: Mr. Madhur AgrawalFor Respondent: Mr. Manoj Kumar, CIT-DR
Section 234ASection 234B

Hearing : 08/05/2024 : 13/05/2024 Date of pronouncement ORDER PER OM PRAKASH KANT, AM These two appeals by the assessee are directed against two separate final assessment orders dated 03.04.2021 and 09.02.2022, passed by the Ld. Assessing Officer, National E- Marsh India Insurance Brokers Pvt. Ltd. Marsh India Insurance Brokers ... case, the assessee filed an add In the case, the assessee filed an additional ground challenging the limitation in passing the final assessment order challenging the limitation in passing the final assessment order challenging the limitation in passing the final assessment order following the decision of the Hon’ble Bombay

Conferencecall Services India Private Ltd, Bangalore vs. DCIT, Corporate Circle -1(2), Chennai

In the result, appeal filed by the assessee is allowed

ITA 319/CHNY/2018[2013-14]Status: DisposedITAT Chennai10 May 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.319/Chny/2018 िनधा"रणवष"/Assessment Year: 2013-14 V. M/S.Conferencecall – The Dy. Commissioner- Services India Pvt. Ltd., Of Income Tax, Rmz Titanium, No.135, 1St Floor, Corporate Circle-1(2), Old Airport Road, Chennai. Bangalore-560 017. [Pan: Aaccc 6574 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Soumen Adhak (Virtual)For Respondent: Shri A. Sasikumar, CIT
Section 143(3)Section 144C(13)

assessee’s appeal reads as under: 1.1 That on the facts and circumstances of the case, since the Ld. AO has passed the final assessment order after expiry of one month from the end of the month in which the directions of the Honorable Dispute Resolution Panel (Ld. DRP) were ... Rs.7,53,90,367/-. ITA No.319/Chny/2018 for AY 2013-14 M/s.Conferencecall Services India Pvt. Ltd. :: 3 :: Pursuant thereto, the AO passed the impugned final assessment order on 21.11.2017 u/s.143(3) r.w.s.144C(1) r.w.s.92CA of the Act. 4. Assailing the action of the AO to have passed the final assessment order

DCIT, Chennai vs. Empee Distilleries Ltd., Chennai

In the result, appeal filed by the Revenue is dismissed

ITA 1380/CHNY/2017[2007-08]Status: DisposedITAT Chennai10 May 2024AY 2007-08

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपीलसं./I.T.A.No.1380/Chny/2017 (िनधा"रण वष" / Assessment Year: 2007-08) Vs M/S. Empee Distilleries Ltd. The Deputy Commissioner Of Income Tax, ‘Empee Tower, Corporate Circle-2(1) 59, Harris Road, Pudupet, Chennai-600 034 Chennai-600 002. Pan : Aaace-1687-N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/ Appellant By : Mr. Suresh Guduri, Jcit ""यथ"क"ओरसे/Respondent By : Mr. A.R.Karthick Lakshmanan, Advocate सुनवाईक"तारीख/Date Of Hearing : 25.04.2024 घोषणाक"तारीख /Date Of Pronouncement : 10.05.2024 आदेश आदेश / O R D E R आदेश आदेश

For Appellant: Mr. Suresh Guduri, JCITFor Respondent: Mr. A.R.Karthick
Section 147

reopened the assessment recording reasons on claim of exempt income and non debit of any expenditure to earn exempt income. However, in final assessment order no addition has been made on the issue for which case was reopened. The Assessing Officer in the assessment order has made addition on account

Mcafee Software India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bengaluru

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

ITA 110/BANG/2024[2017-18]Status: DisposedITAT Bangalore10 May 2024AY 2017-18

Bench: Shri George George K & Shri Waseem Ahmed

For Appellant: Shri. Aliasgar Rampurawala, CAFor Respondent: Shri. Satish Meriga, CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 250Section 25oSection 36(1)(va)Section 40Section 43B

Dispute Resolution Panel (DRP). The DRP vide its directions dated 16.06.2022 disposed of the assessee's objections. Pursuant to the DRP's directions, Final Assessment Order (FAO) was passed, accepting the returned income. Therefore, the TP adjustment and the disallowance under section 40(a)(ia) of the Act, was deleted ... argument of the learned AR during the hearing before ITAT in ITA No.912/Bang/2022 was that the computation sheet attached to the final assessment order, the AO has taken into account not the returned income but the total income computed as per the intimation under section

Home Credit International A.S., Czech Republic vs. Assistant. Deputy Commissioner of Income Tax, International Taxation, Gurgaon

In the result, appeal is partly allowed, as indicated above

ITA 2068/DEL/2023[2020-2021]Status: DisposedITAT Delhi10 May 2024AY 2020-2021

Bench: Shri Saktijit Dey, Vice- & Shri Pradip Kumar Kediaassessment Year: 2020-21

Section 143(3)Section 144C(13)Section 9(1)(vi)

Date of hearing 25.04.2024 Date of pronouncement 10.05.2024 ORDER PER SAKTIJIT DEY, VICE-PRESIDENT Captioned appeal by the assessee arises out of the final assessment order dated 30.05.2023 passed under section 143(3) read with section 144C(13) of the Income-tax Act, 1961 (in short ‘the Act’) pertaining ... Though, the assessee has raised multiple grounds, however, at the outset, the assessee has raised a pertinent issue questioning the validity of the final assessment order due to non- implementation of the directions of learned DRP. 3. Briefly the facts relating to this issue are, the assessee