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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

Asus India Private Limited, Mumbai vs. Income Tax Officer-9(1)(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7147/MUM/2017[2013-14]Status: DisposedITAT Mumbai14 Jun 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm आयकरअपीलसं./ I.T.A. No.7147/Mum/2017 (ननधधारणवर्ा / Assessment Year: 2013-14) Asus India Private Ito Ward- 9(1) (4), Limited. Mumbai. 402, Supreme Chamber, बनाम/ Veera Desai Road, Vs. Andheri West, Mumbai-400 053. स्थधयीलेखधसं./जीआइआरसं./ Pan No Aajca 6450C (अपीलधथी/Appellant) (प्रत्यथी / Respondent) : अपीलधथी की ओरसे/ Appellant By : Dhanesh Bafna, Pratik Shah, Ms. Tejal Saraf, Ms. Riddhi M Maru Shri Anoop Hiwase (Sr. Dr) प्रत्यथी की ओरसे/Respondent By : सुनवधई की तधरीख/ 21.03.2023 : Date Of Hearing घोर्णध की तधरीख/ 14.06.2023 : Date Of Pronouncement आदेश / O R D E R Per Prashant Maharishi: 1) This Appeal Is Filed By Asus India Private Limited [Assessee/ Appellant] Against The Assessment Order Passed U/S 144C (13) R.W.S 143(3) Of The Act, 1961 On 26Th October, 2017 For Assessment Year 2013-14. 2 I.T.A. No. 7147/Mum/2017 Asus India Private Limited Vs. Ito

For Appellant: Dhanesh Bafna, Pratik Shah
Section 115JSection 144CSection 92C

assessee preferred an objection before the Ld. Dispute Resolution Penal-1 (WZ), Mumbai, (DRP). The DRP passed direction on 22/09/2017. 6) Consequently, the final assessment order was passed on 26th October, 2017 determining the total income of assessee at Rs.9,53,12,786/-. The book profit was also computed ... beyond the time limit prescribed and, therefore, the draft 4 I.T.A. No. 7147/Mum/2017 Asus India Private Limited vs. ITO assessment order and final assessment order dated 26th October, 2017 is time barred and, therefore, liable to be quashed. 9) The Ld. AR vehemently submitted that this ground is available

Johnson &Johnson P.Ltd, Mumbai vs. The DCIT/ACIT/Jt/ITO/NFAC, Delhi

ITA 1740/MUM/2021[2016-17]Status: DisposedITAT Mumbai13 Jun 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Shri M.P. Lohia, ARFor Respondent: Ms. Vranda U. Matkari, DR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 153Section 92CSection 93C

hence, the order passed under Section 143(3) read with Section 144C(13) is also barred by limitation and ought to be quashed. Final assessment order barred by limitation 42. On the facts and circumstances of the case and in law, the learned AO erred in not appreciating that ... time limit prescribed under section 153 is the outer time limit for passing the final assessment order and hence, the final assessment order dated 26 February 2016 is time barred and liable to be quashed. The Appellant craves leave to add, alter, modify or delete or modify the above grounds

ACIT (Ltu)-1, Mumbai vs. Johnson & Johnson Pvt. Ltd.(Frmerly Known As Johnson & Johnson Ltd.), Mumbai

ITA 3015/MUM/2016[2011-12]Status: DisposedITAT Mumbai13 Jun 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Shri M.P. Lohia, ARFor Respondent: Ms. Vranda U. Matkari, DR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 153Section 92CSection 93C

hence, the order passed under Section 143(3) read with Section 144C(13) is also barred by limitation and ought to be quashed. Final assessment order barred by limitation 42. On the facts and circumstances of the case and in law, the learned AO erred in not appreciating that ... time limit prescribed under section 153 is the outer time limit for passing the final assessment order and hence, the final assessment order dated 26 February 2016 is time barred and liable to be quashed. The Appellant craves leave to add, alter, modify or delete or modify the above grounds

Johnson & Johnson Pvt. Ltd., Mumbai vs. ACIT - Ltu-1, Mumbai

ITA 2779/MUM/2016[2011-12]Status: DisposedITAT Mumbai13 Jun 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Shri M.P. Lohia, ARFor Respondent: Ms. Vranda U. Matkari, DR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 153Section 92CSection 93C

hence, the order passed under Section 143(3) read with Section 144C(13) is also barred by limitation and ought to be quashed. Final assessment order barred by limitation 42. On the facts and circumstances of the case and in law, the learned AO erred in not appreciating that ... time limit prescribed under section 153 is the outer time limit for passing the final assessment order and hence, the final assessment order dated 26 February 2016 is time barred and liable to be quashed. The Appellant craves leave to add, alter, modify or delete or modify the above grounds

Nuovo Pignone International Srl, Gurgaon vs. DCIT, Circle-2(2)(2), Delhi

In the result, appeal is allowed as indicated above

ITA 999/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Jun 2023AY 2018-19

Bench: Shri G.S. Pannu & Shri Saktijit Deyassessment Year: 2018-19 Nuovo Pignone International Versus Dcit, Circle 2(2)(2), Srl, 6Th Floor, Building No. 7A, International Taxation, Standard Chartered Building, New Delhi Dlf Cyber City, Phase-Iii, Gurgaon. Pan: Aabcg3212A (Appellant) (Respondent)

For Appellant: Sh. Sachit Jolly, Advocate &For Respondent: Sh. Virendra Singh, Sr. DR
Section 133ASection 143(3)Section 144C(13)

Date of hearing : 19.05.2023 Date of pronouncement: 13.06.2023 ORDER PER SAKTIJIT DEY, J.M.: Captioned appeal has been filed by the assessee challenging the final assessment order dated 14.03.2022 passed by the Assessing Officer u/s. 143(3) read with section 144C(13) of the Income-tax Act, 1961 for the assessment

Adm Agro Industries Kota & Akola P.Ltd, Gurugram vs. ACIT, Circle-1(1), New Delhi

In the result, appeal is partly allowed

ITA 2281/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Jun 2023AY 2018-19

Bench: Shri G.S. Pannu & Shri Saktijit Deyassessment Year: 2018-19 Adm Agro Industries Kota & Versus Acit, Circle 1(1), Akola P. Ltd., 3Rd Floor, Vatika New Delhi Professional Point, Golf Course Extension Road, Sector-66, Gurgaon. Pan: Aabcs9646L (Appellant) (Respondent)

For Appellant: Sh. Ajay Vohra, Sr. Advocate &For Respondent: Sh. Rajesh Kumar, CIT-DR
Section 143(3)Section 144C(13)

Date of hearing : 15.03.2023 Date of pronouncement : 13.06.2023 ORDER PER SAKTIJIT DEY, J.M.: Captioned appeal has been filed by the assessee challenging the final assessment order dated 21.07.2022 passed u/s. 143(3) read with section 144C(13) of the Income-tax Act, 1961 pertaining to assessment year

Qualcomm Incorporated, Hyderabad vs. DCIT, Circle- 3(1)(1), Intl. Taxation, New Delhi

The appeal of the assessee is allowed

ITA 7559/DEL/2018[2015-16]Status: DisposedITAT Delhi13 Jun 2023AY 2015-16

Bench: Shri G.S. Pannu & Shri Saktijit Dey

For Appellant: Sh. Percy J. Pardiwala, Sr. CounselFor Respondent: Sh. Gangadhar Panda, CIT(DR)
Section 143(3)Section 144C(13)Section 9(1)(vi)

Date of hearing : 24.03.2023 Date of pronouncement : 13.06.2023 ORDER PER SAKTIJIT DEY, J.M.: Captioned appeals have been filed by the assessee challenging the final assessment orders passed u/s. 143(3) read with section 144C(13) of the Income-tax Act, 1961 pertaining to assessment years

Qualcomm Incorporated, Usa vs. DCIT, Circle- 3(1)(1), Intl. Taxation, New Delhi

The appeal of the assessee is allowed

ITA 7894/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Jun 2023AY 2014-15

Bench: Shri G.S. Pannu & Shri Saktijit Dey

For Appellant: Sh. Percy J. Pardiwala, Sr. CounselFor Respondent: Sh. Gangadhar Panda, CIT(DR)
Section 143(3)Section 144C(13)Section 9(1)(vi)

Date of hearing : 24.03.2023 Date of pronouncement : 13.06.2023 ORDER PER SAKTIJIT DEY, J.M.: Captioned appeals have been filed by the assessee challenging the final assessment orders passed u/s. 143(3) read with section 144C(13) of the Income-tax Act, 1961 pertaining to assessment years

Smit Singapore Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax(Int Taxation)-4(2)(1), Mumbai

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

ITA 816/MUM/2023[2020-2021]Status: DisposedITAT Mumbai12 Jun 2023AY 2020-2021

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur Agrawal a/w Ms. Miti ShahFor Respondent: Shri Chandip Singh
Section 142(1)Section 143(2)Section 143(3)Section 144C(5)Section 234Section 234ASection 234BSection 270ASection 44BSection 9(1)(vi)

12/06/2023 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been filed by the assessee challenging the impugned final assessment order dated 18/01/2023, passed under section 143(3) r/w 144C(13) of the Income Tax Act, 1961 ("the Act"), pursuant to the directions dated 27/12/2022 ... rejected the objections filed by the assessee. 8. In conformity with the directions issued by the learned DRP, the AO, vide impugned final assessment order dated 18/01/2023, assessed the receipts Smit Singapore Pte. Ltd. ITA no.816/Mum./2023 from chartering as Royalty. Being aggrieved, the assessee is in appeal before

Marriott International Inc., Mumbai vs. Dy, CIT (International Tax) 3(2)(1), Mumbai

In the result, appeal by the assessee is allowed

ITA 1784/MUM/2022[2010-11]Status: DisposedITAT Mumbai12 Jun 2023AY 2010-11

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.1784/मुं/ 2022 ("न.व.2010-11) Marriott International Inc C/O.Marriott Hotels India Private Limited 303A, 304, Fulcrum, B Wing, Hiranandani Business Park, Sahar Road, Andheri(E), Mumbai 400 099 Pan: Aaecm-8040-K ...... अपीलाथ" /Appellant बनाम Vs. Deputy Commissioner Of Income-Tax (International Tax)-3(2)(1), Mumbai, 16Th Floor, Air India Building, Nariman Point,Mumbai 400 007. ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : S/Shri Paras Savla & Pratik Poddar ""तवाद" "वारा/Respondent By : Shri Soumendu Kumar Dash सुनवाई क" "त"थ/ Date Of Hearing : 31/05/2023 घोषणा क" "त"थ/ Date Of Pronouncement : 12/06/2023

For Appellant: S/Shri Paras Savla & Pratik PoddarFor Respondent: Shri Soumendu Kumar Dash
Section 143(3)Section 144C

NO.2217/Mum/2016. In the meantime, the Assessing Officer in pursuance to 3 the direction of CIT(A) vide order dated 30/11/2015 passed the final assessment order on 29/12/2016 without passing the draft assessment order. Against the said assessment order, the assessee filed appeal before the CIT(A). The CIT(A) affirmed ... dated 12/08/2023. The appeal of the assessee in ITA No.1830/Mum/2021 was decided vide order dated 20/02/2023. The Tribunal held the final assessment order sans draft assessment order is invalid. Parallelly, the Assessing Officer pursuant to the directions of the Tribunal vide order dated 09/03/2018 in ITA No.2217/Mum/2016 passed the assessment

Tpg Growth II Makets Pte Ltd., Mumbai vs. DCIT 4(1)(2), Mumbai

Accordingly, Ground No. 4 raised by the Appellant is partly allowed

ITA 1387/MUM/2022[2017-18]Status: DisposedITAT Mumbai06 Jun 2023AY 2017-18
For Appellant: Shri Dinesh BafnaFor Respondent: Dr. Samuel Pitta
Section 143(3)Section 144C(13)Section 144C(5)Section 5Section 9Section 92C(3)

vide order dated 31/03/2022 partly allowed the aforesaid Objections. Pursuant to the directions given by the DRP, the Assessing Officer passed Final Assessment Order, dated 28/04/2022 granting partial relief to the Appellant by assessing the total income of the Appellant at INR 110,23,62,420/- as against the proposed ... income of INR 115,07,88,560/- in the Draft 6 Assessment Order, dated 15/06/2021. The position after the relief granted in the Final Assessment Order can be summarized as under: Sr. Nature of Adjustment DRP Directions Final Assessment No. TP proposed by TPO Order adjustment

Baker Hughes Energy Technologies Uk Limited, United Kingdom vs. ACIT, Circle-1(1)(2), Int. Taxation, New Delhi

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

ITA 521/DEL/2023[2020-21]Status: DisposedITAT Delhi06 Jun 2023AY 2020-21
For Appellant: Shri Sachit Jolly, AdvocateFor Respondent: Shri Vijay Vasanta, CIT DR
Section 448Section 44B

Resolution Panel does not bear mandatory Document Identification Number ("DIN") in the body of the order and therefore, said order and the consequent final assessment order dated 25.01.2023 are void ab initio. 3. That on the facts and circumstances of the case, the AO erred in holding that the Appellant ... dated ° 1.07.1987 issued by the CBDT. 14. That on the facts and circumstances of the case, the AO erred in the passing the Final Assessment Order based on several factually incorrect findings, despite specific directions in this regard of the DRP in para 3.2.10 of the order dated

Motorola Solutions India Pvt. Ltd., Gurgaon vs. DCIT, Circle- 2, Gurgaon

In the result, Appeal of the Assessee is partly allowed

ITA 672/DEL/2018[2008-09]Status: DisposedITAT Delhi06 Jun 2023AY 2008-09

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Usi.T.A. No. 672/Del/2018 (A.Y 2008-09)

Section 143(2)Section 143(3)Section 147Section 151Section 234BSection 244ASection 271(1)(c)Section 37(1)Section 43B

income of Rs. 9,42,01,184/-, the case of the assessee was selected for scrutiny u/s 143(2) of the Act. A final assessment order came to be passed by computing the total income of the assessee at Rs.440,86,65,970/- on 08/11/2012 u/s 143(3)/144C

Jiostar India Private Limited, Mumbai vs. Asst CIT 16 (1), Mumbai

ITA 7872/MUM/2019[2015-16]Status: FixedITAT Mumbai05 Jun 2023AY 2015-16

Bench: Shri R.S. Syal (V.P.), Shri Aby T. Varkey (J.M.) & Shri Prashant Maharishi (A.M.) आयकर अपील सं. / Ita. No.7872/Mum/2019 "नधा"रण वष" / Assessment Year : 2015-16

Section 255(3)

succor was provided by the Dispute Resolution Panel (DRP), which culminated into making transfer pricing addition of the equal amount in the final assessment order passed by the AO for the A.Y. 2014-15. The Tribunal took note of the fact that the assessee submitted an expert’s opinion ... which 8 Star India Private Limited also relied on its own order for the A.Y. 2014-15. This is how, the final assessment order came to be passed by making transfer pricing adjustment on this international transaction at Rs.2031.50 crore. It is apparent from the above factual panorama that

Lintas India Pvt. Ltd., Mumbai vs. ACIT, Circle- 16(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2018/MUM/2022[2018-19]Status: DisposedITAT Mumbai01 Jun 2023AY 2018-19
Section 143(3)Section 144C(13)Section 14ASection 92CSection 92C(1)

cannot be entertained since the assessee has not made the claim by filing the revised return of income. The Assessing Officer passed the final assessment order as per the directions of the DRP against which the assessee is in appeal before the Tribunal raising the following grounds of appeal

DCIT, CC-2(4), Mumbai vs. Keystone Realtors P Ltd., As Representative Assessee of M/S. Mausmi Ventures Ltd., Mumbai

Appeal of the Revenue is dismissed

ITA 90/MUM/2023[2013-14]Status: DisposedITAT Mumbai31 May 2023AY 2013-14

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.88/मुं/ 2023 से 90/मुं/ 2023 ("न.व.2011-12 से 2013-14)

For Appellant: Smt. Madhumalti Ghosh, CIT DRFor Respondent: Shri Naresh Kumar
Section 131Section 139(1)Section 143(2)Section 143(3)Section 144C(1)Section 144C(3)Section 148Section 163Section 163(1)

r.w.s. 143(3) of the Act in the name of KRPL as representative assessee of MVL. Subsequent thereto, the Assessing Officer passed final assessment order in the name of KRPL as representative assessee of MVL on 08/02/2019. 3.1 Against final assessment order the assessee filed appeal before ... inter-alia, assailing the order of Assessing Officer in passing final assessment order u/s. 144C(3) r.w.s. 143(3) and 147 of the Act treating KRPL as a representative assessee of MVL. The CIT(A) after considering facts of the case and various decisions cited by the assessee held

DCIT, CC-2(4), Mumbai vs. Keystone Realtors P Ltd., As Representative Assessee of M/S. Mausmi Ventures Ltd., Mumbai

Appeal of the Revenue is dismissed

ITA 89/MUM/2023[2012-13]Status: DisposedITAT Mumbai31 May 2023AY 2012-13

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.88/मुं/ 2023 से 90/मुं/ 2023 ("न.व.2011-12 से 2013-14)

For Appellant: Smt. Madhumalti Ghosh, CIT DRFor Respondent: Shri Naresh Kumar
Section 131Section 139(1)Section 143(2)Section 143(3)Section 144C(1)Section 144C(3)Section 148Section 163Section 163(1)

r.w.s. 143(3) of the Act in the name of KRPL as representative assessee of MVL. Subsequent thereto, the Assessing Officer passed final assessment order in the name of KRPL as representative assessee of MVL on 08/02/2019. 3.1 Against final assessment order the assessee filed appeal before ... inter-alia, assailing the order of Assessing Officer in passing final assessment order u/s. 144C(3) r.w.s. 143(3) and 147 of the Act treating KRPL as a representative assessee of MVL. The CIT(A) after considering facts of the case and various decisions cited by the assessee held

DCIT, CC-2(4), Mumbai vs. Keystone Realtors P Ltd As Representative Assessee of M/S. Mausmi Ventures Ltd.), Mumbai

Appeal of the Revenue is dismissed

ITA 88/MUM/2023[2011-12]Status: DisposedITAT Mumbai31 May 2023AY 2011-12

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.88/मुं/ 2023 से 90/मुं/ 2023 ("न.व.2011-12 से 2013-14)

For Appellant: Smt. Madhumalti Ghosh, CIT DRFor Respondent: Shri Naresh Kumar
Section 131Section 139(1)Section 143(2)Section 143(3)Section 144C(1)Section 144C(3)Section 148Section 163Section 163(1)

r.w.s. 143(3) of the Act in the name of KRPL as representative assessee of MVL. Subsequent thereto, the Assessing Officer passed final assessment order in the name of KRPL as representative assessee of MVL on 08/02/2019. 3.1 Against final assessment order the assessee filed appeal before ... inter-alia, assailing the order of Assessing Officer in passing final assessment order u/s. 144C(3) r.w.s. 143(3) and 147 of the Act treating KRPL as a representative assessee of MVL. The CIT(A) after considering facts of the case and various decisions cited by the assessee held

DCIT -5(2) (1), Mumbai vs. Kec International Ltd, Mumbai

Accordingly, Ground No. 3.1 & 3.2 raised by the Assessee are dismissed

ITA 33/MUM/2022[2013-14]Status: DisposedITAT Mumbai31 May 2023AY 2013-14
For Appellant: Shri Vijay MehtaFor Respondent: Shri Pravin Shekhar
Section 143(3)Section 144C(3)

Appellant prays that the draft assessment order be held as bad in law and consequently, the assessment proceedings and the final assessment order be quashed. 2. Transfer pricing addition on corporate guarantee: 2.1. On the facts and circumstances of the case and in law, the DRP erred in conforming ... Secondary Education Cess made for the first time before the DRP. As per the directions issued by the DRP vide order, dated 27/12/2021, Final Assessment Order, dated 21/01/2022, was passed under Section 143(3) read with Section 30 ITA No. 2453/Mum/2021 (AY 2013-14) 144C(13) and 144B

Maneken Keshvalla Patel, Mumbai vs. Income Tax Department, Ministry of Finance, Delhi

ITA 1107/MUM/2022[2011-12]Status: DisposedITAT Mumbai31 May 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2011-12 Maneken Keshvalla Patel, National Faceless Appeal 1 Manekkunj, Anandpur Vas Centre (Nfac) Vs. At Pundhara Ta : Mansa- Income Tax Department, 382855 Gandhiangar, Gujarat Ministry Of Finance, India-382855 Delhi-110001. Pan No. Alfpp 7410 D Appellant Respondent Assessee By : Mr. Mehul Talera, Ar Revenue By : Ms. Richa Gulati, Dr : Date Of Hearing 25/05/2023 : Date Of Pronouncement 31/05/2023 Order

For Appellant: Mr. Mehul Talera, ARFor Respondent: Ms. Richa Gulati, DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

however same were not responded by the assessee. The Assessing Officer also issued a final show cause notice on 17/12/2018 and passed the final assessment order on 20/12/2018 under section 147 read with section 143(3) of the Act and added the deposits of Rs.63,76,868/- as unexplained cash