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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

Edenred Pte Ltd, Mumbai vs. DCIT It 2 (2) (1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3231/MUM/2023[2020-21]Status: DisposedITAT Mumbai12 Apr 2024AY 2020-21

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopaledenred Pte. Ltd. Vs. Deputy Commissioner Of C/O, Walker Chandiok & Income-Tax, International Co. Llp, 11Th Floor, Tower Taxation-2(2)(1) Ii, One International Room No.1722,17Th Floor, Center, S.B. Marg, Air India Building, Prabhadevi (West), Nariman Point, Mumbai Mumbai – 400013 Maharashtra – 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aacce8636P Appellant .. Respondent Appellant By : Jitendra Singh Respondent By : Anil Sant Date Of Hearing 13.03.2024 Date Of Pronouncement 12.04.2024

For Appellant: Jitendra SinghFor Respondent: Anil Sant
Section 143(3)Section 144C(13)

vide order dated 27.06.2023 rejected the objection filed by the assessee and directed the assessing officer to pass the final assessment order as per the draft proposed in terms of provisions of Sec. 144C(13) of the Act. Thereafter the assessing officer has passed final assessment order ... total income of the assessee. The learned DRP rejected the objections filed by the assessee. In conformity, the AO passed the impugned final assessment order. Being aggrieved, the assessee is in appeal before us. 5. The issue arising in ground No. 1 is general in nature and therefore needs

Yogesh Kotiyal, New Delhi vs. ACIT Circle Int Tax 2(1)2, New Delhi

In the result, the appeal of the assessee is allowed

ITA 391/DEL/2023[2020-21]Status: DisposedITAT Delhi12 Apr 2024AY 2020-21

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

For Appellant: Ms. Preeti Goel, AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144C(13)Section 244ASection 270ASection 5(2)(a)Section 6(1)Section 9Section 9(1)(ii)Section 90

directions of the Hon'ble DRP, in the facts and circumstances of the case and in law erred in issuing the impugned Final Assessment Order dated 21 December 2022 under Section 143(3) read with Section 144C(13) of the Act disallowing the exemption of INR 55,37,591 claimed ... employment was executed in India and employment was based in India throughout his Australia assignment. 19. The Assessing Officer has thereafter issued final assessment order under Section 144C(13) read with Section 143(3) of the Act on 21 December 2022 and disallowed the claim for relief on ground that

Advics Company Ltd., Karnataka vs. ACIT Circle International Taxation-1(1)(1), Delhi

In the result, appeal of the assessee is allowed

ITA 1053/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Apr 2024AY 2017-18

Bench: SHRI G.S. PANNU (Vice President), MS. ASTHA CHANDRA (Judicial Member)

For Appellant: Shri K.M. Gupta, AdvFor Respondent: Shri Vijay B. Vasanta, CIT-DR
Section 143(3)Section 192Section 234BSection 270ASection 9(1)(vii)

Date of 12.04.2024 pronouncement: O R D E R PER ASTHA CHANDRA, JM The appeal filed by the assessee is directed against the final assessment order dated 19.03.2022 passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the “Act”) in pursuance to the directions ... erred in initiating penalty proceedings under Section 270A of the Act against the Appellant on account of the addition made in the final assessment order. All the above grounds are without prejudice to each other. The Appellant craves leave to add, amend, vary, omit or substitute any of the aforesaid

Axis Bank Limited, Ahmedabad vs. Assistant Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad

The appeal of the assessee is partly allowed for statistical purposes

ITA 365/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2018-19

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2018-19 Axis Bank Limited, Vs. Assistant Commissioner Of “Trishul”, 3Rd Floor, Opp. Income-Tax, Samartheshwar Temple, Nr. Law Circle 1(1)(1), Garden, Ellisbridge, Ahmedabad Ahmedabad-380006 Pan : Aaacu 2414 K अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Dr. Darsi Suman Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.11.2023/03.04.2024 घोषणा क" तारीख /Date Of Pronouncement: 10.04.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: By Way Of This Appeal, The Assessee-Appellant Has Challenged Correctness Of The Order Dated 28Th July, 2022 Passed By The Assessing Officer Under Section 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act” For Short], For The Assessment Year (Ay) 2018-19. 2. Ground No.1 Raised By The Assessee Reads As Under:- “1. Disallowance In Respect Of Annual Technical Fees (Tax Effect - Rs. 16,84,276) 1.1 The Learned Drp Has Erred In Upholding Addition Made By Ao In Respect Of Treating Annual Technical Services (Ats) Fees Paid To Infosys Limited To The Extent Of Rs. 48.66 Lacs As Prior Period Expense. 1.2. It Is Submitted That The Expenditure Relates To Amount Payable To Infosys & No Part Of The Amount Was Claimed As Expenditure At Any Time In The 2 Axis Bank Limited Vs. Acit Ay : 2018-19

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Dr. Darsi Suman Ratnam, CIT-DR
Section 143(3)Section 144C

continuation of assessment proceeding as it is only the draft assessment order which is being challenged before it. The final assessment order is yet to be passed by the assessing officer. Hence, the DRP is not an appellate authority and the proceeding before the DRP is continuation of assessment proceedings ... Taxman 0166 (Bom), held that: “47. However as no final assessment order has yet been passed by the Assessing officer and the issues are still at large before the DRP the same could be urged before the DRP……………………………… …….. … …………………. . The process before the DRP is a continuation of the assessment proceedings

Sunil Kapoor, New Delhi vs. ACIT Circle Intl. Taxation 2(1)(2), New Delhi

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

ITA 3314/DEL/2023[2021-22]Status: DisposedITAT Delhi08 Apr 2024AY 2021-22

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2021-22 Shri Sunil Kapoor, Vs. Acit K-77, Lajpat Nagar-Ii, Circle Intt. New Delhi-110 024 Taxation 2(1)(2) Pan Aoips5698J New Delhi. (Appellant) (Respondent)

For Appellant: Shri Rajiv Tyagi, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)

Date of 08.04.2024 pronouncement: O R D E R PER ASTHA CHANDRA, JM The appeal filed by the assessee is directed against the final assessment order of Ld. Asstt. Commissioner of Income Tax, Circle Int. Tax (2)(1)(2) New Delhi (“AO”) dated 25.09.2023 passed under section 143(3) r.w.s ... lakhs each paid to three parties and the indexed cost of improvement of Rs. 1,31,57,486/-. In 7 the final assessment order passed pursuant to directions of the Ld. DRP, the Ld. AO negatived the claim of deduction of transfer expenses in full and disallowed the claim

Ayesa Ingenieria Y Arquitectura S.A., Noida vs. ACIT Intl. Taxation, Gurgaon

In the result, appeal of the assessee is allowed

ITA 2174/DEL/2023[2021-22]Status: DisposedITAT Delhi08 Apr 2024AY 2021-22

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

For Appellant: Shri Vivek Sarin, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 192BSection 195Section 201Section 40Section 7(3)

pronouncement: O R D E R PER ASTHA CHANDRA, JM Both the appeals filed by the assessee are directed against two separate final assessment orders dated 31.05.2023 and 30.05.2023 passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the “Act”) in pursuance to the directions ... separate notification with respect to the same. 3.2 Pursuant to the directions of the Ld. DRP, the Ld. AO passed the final assessment order under section 143(3) r.w. section 144C(13) of the Act making an addition

Ayesa Ingenieria Y Arquitectura S.A., Noida vs. ACIT Intl. Taxation, Gurgaon

In the result, appeal of the assessee is allowed

ITA 2173/DEL/2023[2020-21]Status: DisposedITAT Delhi08 Apr 2024AY 2020-21

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

For Appellant: Shri Vivek Sarin, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 192BSection 195Section 201Section 40Section 7(3)

pronouncement: O R D E R PER ASTHA CHANDRA, JM Both the appeals filed by the assessee are directed against two separate final assessment orders dated 31.05.2023 and 30.05.2023 passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the “Act”) in pursuance to the directions ... separate notification with respect to the same. 3.2 Pursuant to the directions of the Ld. DRP, the Ld. AO passed the final assessment order under section 143(3) r.w. section 144C(13) of the Act making an addition

Ambereen Islam., Kolkata vs. ACIT, Cir- 40, Kolkata.

In the result appeal of the assessee is allowed

ITA 1222/KOL/2023[2014-15]Status: DisposedITAT Kolkata05 Apr 2024AY 2014-15

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(2)Section 143(3)

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

Shell Information Technology International Bv, Mumbai vs. DCIT (It) 4 (2) (1), Mumbai

ITA 3339/MUM/2023[2020-21]Status: DisposedITAT Mumbai04 Apr 2024AY 2020-21
For Appellant: Shri Madhur AgarwalFor Respondent: Shri Ajay Kumar Sharma
Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 2(24)Section 234ASection 234BSection 270A

Date Conclusion of hearing : 22.02.2024 Pronouncement of order : 04.04.2024 ORDER Per Rahul Chaudhary, Judicial Member: 1. The present appeal is directed against the Final Assessment Order dated, 27/07/2023, pertaining to the Assessment Year 2020-2021 passed under Section 143(3) read with Section 144C(13) of the Income ... assessing the total income at Rs. 3,09,31,07,476 as against Rs. 2,41,13,630 offered by the Appellant, Final assessment order passed by the learned AO is bad in law 2 On the facts and circumstances of the case and in law, the learned AO erred

Thermax Babcock & Wilcox Energy Solution Limited, Mumbai vs. Addl/Jt/Dy/CIT/Asstt/ITO/NFAC, Delhi

ITA 739/MUM/2022[2017-18]Status: DisposedITAT Mumbai04 Apr 2024AY 2017-18

Bench: Shri Vikas Awasthy & Shri Amarjit Singh, Accountαντ Μεμβer

For Appellant: Dhanesh Bafna a/wFor Respondent: Anil Sant

Page 1 ITA No.739/Mum/2022 Thermax Babcock & Wilcox Energy Solutions Ltd. Vs. DCIT, Circle 2(3)(1) IN THE INCOME TAX

Hcl Honh Kong Sar Ltd, New Delhi vs. ACIT, Circle 2(1)(1), International Taxation, New Delhi

ITA 77/DEL/2023[2013-14]Status: DisposedITAT Delhi29 Mar 2024AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Axon Solutions Limited, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 575/DEL/2023[2018-19]Status: DisposedITAT Delhi29 Mar 2024AY 2018-19

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Axon Solutions Limited, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 574/DEL/2023[2017-18]Status: DisposedITAT Delhi29 Mar 2024AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Axon Solutions Limited, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 573/DEL/2023[2016-17]Status: DisposedITAT Delhi29 Mar 2024AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Axon Solutions Limited, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 572/DEL/2023[2015-16]Status: DisposedITAT Delhi29 Mar 2024AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Axon Solutions Limited, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 571/DEL/2023[2014-15]Status: DisposedITAT Delhi29 Mar 2024AY 2014-15

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Axon Solutions Limited, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 570/DEL/2023[2013-14]Status: DisposedITAT Delhi29 Mar 2024AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Hcl Great Britain Ltd, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 569/DEL/2023[2017-18]Status: DisposedITAT Delhi29 Mar 2024AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Hcl Great Britain Ltd, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 568/DEL/2023[2016-17]Status: DisposedITAT Delhi29 Mar 2024AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023

Hcl Great Britain Ltd, New Delhi vs. ACIT Circle International Tax 2(1)(1), New Delhi

ITA 567/DEL/2023[2015-16]Status: DisposedITAT Delhi29 Mar 2024AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

also under the Double Taxation Avoidance Agreement. The assessee filed objections before the DRP wherein partial relief was granted and, subsequently, the impugned final assessment orders were passed for which the assessee are in appeal. 2.1 The case set up by the appellants is that they and HCLT are part ... Netherlands 2017-18 554/DEL/2023 9. HCL Singapore Pte Ltd 2016-17 558/DEL/2023 10. HCL Australia services Pty ltd 2016-17 563/DEL/2023 (iii) Final Assessment Order passed in the name of non-existing entity S.No. Name of the company AYs ITA No. 1. HCL Technologies (Pty) Ltd 2013-14 423/DEL/2023