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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

Venkatesh Bomma, Hyderabad vs. ITO., (Int Taxn)-1, Hyderabad

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

ITA 62/HYD/2024[A Y 2014-15]Status: DisposedITAT Hyderabad09 May 2024

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.62/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Sri Venkatesh Bomma Vs. Income Tax Officer Hyderabad (International Taxation)-1 Pan:Afhpb6561K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Rajeshwara Rao, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 08/05/2024 घोषणा की तारीख/Pronouncement: 09/05/2024 आदेश/Order

For Appellant: Shri P Rajeshwara Rao, CAFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 144(1)Section 147Section 148Section 50C

Rs.35,28,035/- on the ground that the assessee could not substantiate its claim with necessary evidences. Thereafter, the Assessing Officer passed the final assessment order and determined the total income at Rs.5,29,077/- towards Long-Term Page 3 of 7 ITA No 62 of 2024 Venkatesh Bomma Capital ... Gain derived from transfer of property and modified the assessment. 6. Aggrieved by the final assessment order, the assessee is in appeal before the Tribunal. 7. The learned Counsel for the assessee Shri P. Rajeshwara Rao, CA submitted that the learned Assessing Officer/DRP erred in not allowing indexed cost

Six Continents Hotels, Inc., Gurgaon vs. ACIT Circle 3(1)(2) Intl. Taxation, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2355/DEL/2023[2020-21]Status: DisposedITAT Delhi09 May 2024AY 2020-21

Bench: Dr. B. R. R. Kumar, Sh. Yogesh Kumar Us

For Appellant: Sh. S. K. Aggarwal, CA &For Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 9(1)(vii)

name and taxable as Fees for Included Services (‘FIS’) under Article 12(4)(a) of India-US DTAA (internal page 16 of the final assessment order at page 25 of the appeal set). In making the above allegation in the draft order, the AO referred the agreement with Duet Hotels ... chargeable to tax. However, the AO may discuss the new business model, which has come into existence with effect from 01.04.2019, in the final assessment order”. 14. Thus, the Id. DRP following the orders of earlier years held that marketing and reservation related receipts are ancillary and subsidiary to Royalty

Key Point Technologies (India) Private Limited, Hyderabad vs. ACIT, Circle 2(1), Hyderabad

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

ITA 252/HYD/2021[2016-17]Status: DisposedITAT Hyderabad08 May 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha, G. Hon’Ble Accounant Member Assessment Year: 2016-17 Key Point Technologies Vs. The Assistant Commissioner (India) Private Limited, Of Income Tax, Rajaprasadamu, Circle – 2(1), Level 2, Wing 1B & 2, Hyderabad. Botanical Gardens Road, Kondapur, Hyderabad – 500 084. Pan : Aadck1115A (Appellant) (Respondent) Assessee By: Shri Ravi Bharadawaj, C.A. Revenue By: Shri Kumar Pranav, Cit-Dr Date Of Hearing: 06.05.2024 Date Of Pronouncement: 08.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2016-17 Arises From The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dt.23.04.2021 Invoking Proceedings Under Section 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (In Short, “The Act”). 2. The Brief Facts Of The Case Are That Assessee Is A Company Engaged In The Development Of Mobile Application Software – User Interface Technology. The Assessee Company Filed Its Return Of Income For A.Y. 2016-17 On 30.11.2016 Admitting A Loss Of Rs.84,13,338/- & Deemed Total Income U/S 115Jb Of The Act Was Admitted At (-) Rs.84,83,289/-. The Return Filed Was Taken Up For Limited Scrutiny To Verify Whether Value Of International Transactions Is Correctly Shown In Form 3Ceb & Return Of Income. Accordingly, A Notice U/S 143(2) Of The Act Was Issued To The Assessee On 17.07.2017. In Response To The Notices, Assessee Furnished Information Called For & The Same Was Verified.

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri Kumar Pranav, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 92C

direction of DRP vide order dt.26.03.2021 and 2 revised the TP adjustment at Rs.4,67,63,043/-. In accordance with the adjustments suggested, final assessment order was passed on 23.04.2021 assessing the total income of the assessee company at Rs.4,62,99,077/-. 3. Feeling aggrieved with final assessment order

M/S. Naturex India Pvt. Ltd, Mumbai vs. NFAC, Delhi DCIT-Cir 2(3) (1), Mumbai

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

ITA 540/MUM/2022[2017-18]Status: DisposedITAT Mumbai08 May 2024AY 2017-18

Bench: Shri Vikas Awasthy & Shri Gagan Goyalm/S. Naturex India Pvt. Ltd. 502, 5Th Floor, Akruti Centre Point, Midc Central Road, Andheri (East), Chakala Midc S.O. Mumbai-400093 Pan: Aabcv0883A ..... Appellant Vs. Nfac, Delhi/Dcit Cir. 2(3) (1) Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ..... Respondent

For Appellant: Shri Aliasger Rampurawala, Shri AmolFor Respondent: Shri Kiran Unavekar, Ld. DR
Section 143(3)Section 144C(13)Section 92

Naturex India Pvt. Ltd. Additional Ground:- Ground No. 3: On the facts and in the circumstances of the case and in law, the final assessment order dated 24 January 2022 passed by the Ld. AO under section 143(3) read with section 144C(13) of the Act is barred ... liable to be quashed. It is humble prayer of the Appellant that the draft assessment order and the final assessment order are bad in law, null and void and liable to be quashed. The Appellant craves leave to add, alter, amend or withdraw all or any of the grounds

Inflight Sales Group India P.Ltd, New Delhi vs. ACIT, Circle-12(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 695/DEL/2020[2015-16]Status: DisposedITAT Delhi08 May 2024AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar, CIT (DR)
Section 143(3)Section 144C(13)

PRADIP KUMAR KEDIA-AM: The captioned appeal has been filed by the assessee seeking to challenge the final assessment order passed by the AO under Section 143(3) r.w. Section 144C(13) order dated 29.10.2019 for A.Y. 2015-16 in question. 2. When the appeal was called for hearing, none

Volvo Information Technology Ab, Sweden vs. DCIT Circle Intl. Taxation 3(1)(1), New Delhi

In the result, the appeal is partly allowed for statistical

ITA 2169/DEL/2023[2020-21]Status: DisposedITAT Delhi07 May 2024AY 2020-21

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2020-21

Section 143(3)Section 144CSection 153(1)

hearing 19.04.2024 Date of pronouncement 07.05.2024 ORDER PER SAKTIJIT DEY, VICE-PRESIDENT Captioned appeal has been filed by the assessee challenging the final assessment order dated 27.06.2023 passed under section 143(3) read with section 144C of the Income-tax Act, 1961 AY: 2020-21 Volvo Information Technology

Subhash Sharma., Belurmath vs. ACIT, Cir-47, Kolkata.

In the result both the appeals of the assessee are allowed

ITA 1100/KOL/2023[2013-14]Status: DisposedITAT Kolkata03 May 2024AY 2013-14

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleita Nos.1099 & 1100/Kol/2023 Assessment Year: 2012-13 & 2013-14 Subhash Sharma Acit, Circle-47, Kolkata 322, Flat-3E, Tirupati Vs Building, G.T. Road, Block-I, Belurmath-711202. Pan: Altps 5888 E (Appellant) (Respondent) Present For: Assessee By : Shri S.L. Kochar & Shri A. Kochar, Ar Revenue By : Shri Partha Pratim Barman, Addl. Cit, Sr. Dr Date Of Hearing : 04.03.2024 Date Of Pronouncement : 03.05.2024 O R D E R Per Sonjoy Sarma: The Captioned Appeals Are Preferred By The Assessee Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-Nfac, Delhi (Hereinafter Referred To As The Ld. Cit(A)”] Both Dated 20.09.2023 For The Ay 2012-13 & 2013-14 Respectively.

For Appellant: Shri S.L. Kochar & Shri A. Kochar, ARFor Respondent: Shri Partha Pratim Barman, Addl. CIT, Sr. DR
Section 143(2)Section 148

before us is on a much stronger footing because leaving aside the issuance of notice u/s 143(2) of the Act, even the final assessment order has been framed by the Assessing Officer not having jurisdiction over the assessee. Though the ld. D/R has referred to the judgment

Subhash Sharma, Belurmath vs. ACIT, Cir-47, Kolkata.

In the result both the appeals of the assessee are allowed

ITA 1099/KOL/2023[2012-13]Status: DisposedITAT Kolkata03 May 2024AY 2012-13

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleita Nos.1099 & 1100/Kol/2023 Assessment Year: 2012-13 & 2013-14 Subhash Sharma Acit, Circle-47, Kolkata 322, Flat-3E, Tirupati Vs Building, G.T. Road, Block-I, Belurmath-711202. Pan: Altps 5888 E (Appellant) (Respondent) Present For: Assessee By : Shri S.L. Kochar & Shri A. Kochar, Ar Revenue By : Shri Partha Pratim Barman, Addl. Cit, Sr. Dr Date Of Hearing : 04.03.2024 Date Of Pronouncement : 03.05.2024 O R D E R Per Sonjoy Sarma: The Captioned Appeals Are Preferred By The Assessee Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-Nfac, Delhi (Hereinafter Referred To As The Ld. Cit(A)”] Both Dated 20.09.2023 For The Ay 2012-13 & 2013-14 Respectively.

For Appellant: Shri S.L. Kochar & Shri A. Kochar, ARFor Respondent: Shri Partha Pratim Barman, Addl. CIT, Sr. DR
Section 143(2)Section 148

before us is on a much stronger footing because leaving aside the issuance of notice u/s 143(2) of the Act, even the final assessment order has been framed by the Assessing Officer not having jurisdiction over the assessee. Though the ld. D/R has referred to the judgment

Computer Modelling Group Limited, Canada vs. ACIT International Taxation Circle 1(2)(1), New Delhi

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2091/DEL/2023[2020-21]Status: DisposedITAT Delhi03 May 2024AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

Section 144C of the Act and accordingly, passed draft assessment order under Section 144C of the Act, and thereafter passing the impugned final assessment order, beyond the period of limitation as prescribed under Section 153 of the Act, thereby making the assessment proceedings barred by limitation. 2. That ... demand under Section 156 of the Act. 2. That on the fact and in circumstances of the case and in law, the final assessment order passed by the Ld. AO is void and liable to be quashed, in the absence of the Document Identification Number (DIN) mentioned on the directions

Computer Modelling Group Limited, Canada vs. DCIT Circle International Taxation 1(2)(1), New Delhi

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2090/DEL/2023[2012-13]Status: DisposedITAT Delhi03 May 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

Section 144C of the Act and accordingly, passed draft assessment order under Section 144C of the Act, and thereafter passing the impugned final assessment order, beyond the period of limitation as prescribed under Section 153 of the Act, thereby making the assessment proceedings barred by limitation. 2. That ... demand under Section 156 of the Act. 2. That on the fact and in circumstances of the case and in law, the final assessment order passed by the Ld. AO is void and liable to be quashed, in the absence of the Document Identification Number (DIN) mentioned on the directions

Jubilant Infrastructure Ltd., Noida vs. ACIT Circle-5 (1)(1), Noida

In the result, the appeal of the assessee is allowed

ITA 949/DEL/2022[2017-18]Status: DisposedITAT Delhi03 May 2024AY 2017-18

Bench: Ms. Madhumita Roy & Sh. Naveen Chandra

Section 115JSection 143Section 32Section 80Section 80I

rate of 25% on Rs. 2,69,20,500 being the WDV for the year under consideration. 3. Ld. Assessing Officer in the final assessment order disallowed the claim of depreciation on intangibles holdings that the facility has been put up by GDIC and assessee is using and not owning

Computer Modelling Group Limited, Canada vs. ACIT, Circle-1(2)(1), Int. Taxation, New Delhi

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2305/DEL/2022[2019-20]Status: DisposedITAT Delhi03 May 2024AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

Section 144C of the Act and accordingly, passed draft assessment order under Section 144C of the Act, and thereafter passing the impugned final assessment order, beyond the period of limitation as prescribed under Section 153 of the Act, thereby making the assessment proceedings barred by limitation. 2. That ... demand under Section 156 of the Act. 2. That on the fact and in circumstances of the case and in law, the final assessment order passed by the Ld. AO is void and liable to be quashed, in the absence of the Document Identification Number (DIN) mentioned on the directions

ITO Ward-51(5), Delhi vs. Ramesh Chander Rajput, Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1189/DEL/2022[2017-18]Status: DisposedITAT Delhi03 May 2024AY 2017-18

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Section 142(1)Section 143(2)Section 68

erroneously printed, assessment order dated 20.12.2019 is null and void. Thus, corrigendum ITO vs. Ramesh Chander Rajput order dated 24.12.2019 is treated as final assessment order u/s 143(3) of the Act. That the Assessee vide an Application under Rule 27 of the Income Tax Appellate Tribunal Rules has challenged ... Assessee and charge a Gross-Profit @18% however, post this SCN (, the Assessee's submissions dated 12.12.2019 were filed and in his Final Assessment Order dated 24.12.2019 (Corrigendum to Assessment Order) Ld. A.O has not rejected the books which clearly evidences that the Ld. A.O. has considered the voluminous documents

Mankind Pharma Limited, Delhi vs. DCIT, Circle-1(1)(1), Meerut

In the result, the additional Ground No

ITA 2313/DEL/2022[2018-19]Status: DisposedITAT Delhi01 May 2024AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Kumar, CIT (DR)
Section 143(3)Section 144BSection 144C(13)Section 153(3)Section 270ASection 35Section 80GSection 80I

PRADIP KUMAR KEDIA-AM: The captioned appeal has been filed at the instance of the assessee against the final assessment order dated 28.07.2022 passed under Section 143(3) r.w. Section 144C(13) r.w. Section 144B of the Income Tax Act (in short ‘the Act’) in pursuance of directions issued ... directions issued. The proposed adjustment was thus brought down from Rs.64,34,78,261/- to Rs.21,92,40,676/-. 13. The AO passed final assessment order dated 28.07.2022 and made additions/disallowances as under: Details of Transaction Amount (in Rs.) TP adjustment w.r.t. specified domestic transaction Adjustment u/s 92CA(3)/80IA

Satish Babu Kannan, Bengaluru vs. ITO, Intnl Taxn Ward-1(2), Chennai

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

ITA 370/CHNY/2023[2015-16]Status: DisposedITAT Chennai30 Apr 2024AY 2015-16

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri D. Anand, Advocate &For Respondent: Shri V. Nandakumar, CIT
Section 142(1)Section 144CSection 147Section 148Section 195

Pronouncement : 30.04.2024 आदेश /O R D E R PER MAHAVIR SINGH, VICE PRESIDENT: This appeal by the assessee is arising out of the final assessment order dated 30.01.2023 passed by the Income Tax Officer, International Taxation 1(2), Chennai u/s.147 r.w.s.144C(13) of the Income Tax Act, 1961 (hereinafter ... well as before the Assessing Officer within 30 days from the date of receipt of Draft Assessment Order.” 3.3 Consequently, the AO framed final assessment order dated 30.01.2023 repeating the same income as under:- a) In view of the above, the total income of assessee is computed as under

Siemens Technology and Services Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, 8(2)(1), Mumbai

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

ITA 725/MUM/2022[2016-17]Status: DisposedITAT Mumbai30 Apr 2024AY 2016-17

Bench: Ms. Kavitha Rajagopal, Jm & Shri Gagan Goyal, Am Siemens Technology & Services Dy. Cit 8(2)(1) Private Limited Mumbai Plot No. 2, Sector 2, Kharghar, Vs. Node, Navi Mumbai- 410 210

For Appellant: Shri Jeet KamdarFor Respondent: Shri Asif Karmali
Section 143(2)Section 144C(13)Section 144C(5)Section 3Section 92C

transfer pricing grounds. 2. The assessee has also raised additional grounds, challenging the validity of the draft assessment order and the final assessment order as being bad-in-law on the grounds of limitation and another additional ground on the limitation based on the decision of the Hon’ble Madras ... vide letter dated 21.12.2020 for giving effect as per the section 144C(13) of the Act. The ld. A.O. then passed the final assessment order dated 27.03.2021 determining the total income at Rs.196,69,70,880/- after making addition on transfer pricing adjustment and other addition/disallowances. 5. Aggrieved, the assessee

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1749/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Apr 2024AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

discussed the affidavit filed by the assessee. n. In the case of Shrivallabh Pittie Industries Limited, for AY 2013-14, in the final assessment order passed, no addition was made. Yet, the Ld. AO has mentioned tax is calculated u/s 115BBE for addition made u/s 68. Further

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1748/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Apr 2024AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

discussed the affidavit filed by the assessee. n. In the case of Shrivallabh Pittie Industries Limited, for AY 2013-14, in the final assessment order passed, no addition was made. Yet, the Ld. AO has mentioned tax is calculated u/s 115BBE for addition made u/s 68. Further

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1747/MUM/2022[2014-15]Status: DisposedITAT Mumbai30 Apr 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

discussed the affidavit filed by the assessee. n. In the case of Shrivallabh Pittie Industries Limited, for AY 2013-14, in the final assessment order passed, no addition was made. Yet, the Ld. AO has mentioned tax is calculated u/s 115BBE for addition made u/s 68. Further

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1746/MUM/2022[2016-17]Status: DisposedITAT Mumbai30 Apr 2024AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

discussed the affidavit filed by the assessee. n. In the case of Shrivallabh Pittie Industries Limited, for AY 2013-14, in the final assessment order passed, no addition was made. Yet, the Ld. AO has mentioned tax is calculated u/s 115BBE for addition made u/s 68. Further