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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

Sime Darby Engineering Sdn Bhd, Delhi vs. The Deputy Commissioner of Income Tax (International Taxation), Circle-1, Dehradun

In the result, appeals of the Assessee in ITA No

ITA 9/DDN/2021[2017-18]Status: DisposedITAT Dehradun27 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(4)

27/01/2026 O R D E R PER MANISH AGARWAL, AM: All the three captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s Sime Darby Engineering SDN BHD vs.DCIT 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short ... appeal raised by the assessee in all the three assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the three captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed

National Oil Well Varco Pte. Ltd (Formerly Known As Varco International Pte. Ltd), Maharashtra vs. The Deputy Director of Income Tax Circle-1( International Taxation ), Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 5/DDN/2021[2017-18]Status: DisposedITAT Dehradun27 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

DCIT O R D E R PER MANISH AGARWAL, AM: All the captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short) subsequent to the direction of Ld. Dispute ... appeal raised by the assessee in all the Five assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed beyond

Sime Darby Engineering Sdnbhd, Malaysia vs. The Deputy Commissioner of Income Tax (International Taxation ) Circle-1, Dehradun

In the result, appeals of the Assessee in ITA No

ITA 40/DDN/2021[2018-19]Status: DisposedITAT Dehradun27 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(4)

27/01/2026 O R D E R PER MANISH AGARWAL, AM: All the three captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s Sime Darby Engineering SDN BHD vs.DCIT 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short ... appeal raised by the assessee in all the three assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the three captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed

National Oilwell Varco Pte. Ltd. (Formerly Known As Varco International Pte Ltd.), Mumbai vs. DCIT (International Taxation), Circle-2, Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 419/DEL/2019[2015-16]Status: DisposedITAT Dehradun27 Jan 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

DCIT O R D E R PER MANISH AGARWAL, AM: All the captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short) subsequent to the direction of Ld. Dispute ... appeal raised by the assessee in all the Five assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed beyond

Sime Darby Engineering Sdn Bhd, Gurgaon vs. DCIT (International Taxation), Circle-2, Dehradun

In the result, appeals of the Assessee in ITA No

ITA 7616/DEL/2018[2015-16]Status: DisposedITAT Dehradun27 Jan 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(4)

27/01/2026 O R D E R PER MANISH AGARWAL, AM: All the three captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s Sime Darby Engineering SDN BHD vs.DCIT 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short ... appeal raised by the assessee in all the three assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the three captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed

National Oilwell Varco Pte. Ltd., Mumbai vs. DCIT (International Taxation), Ci9Rcle-2, Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 5898/DEL/2017[2014-15]Status: DisposedITAT Dehradun27 Jan 2026AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

DCIT O R D E R PER MANISH AGARWAL, AM: All the captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short) subsequent to the direction of Ld. Dispute ... appeal raised by the assessee in all the Five assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed beyond

National Oilwell Varco Pte. Ltd., Mumbai vs. DCIT (International Taxation), Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 1557/DEL/2017[2013-14]Status: DisposedITAT Dehradun27 Jan 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

DCIT O R D E R PER MANISH AGARWAL, AM: All the captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short) subsequent to the direction of Ld. Dispute ... appeal raised by the assessee in all the Five assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed beyond

National Oilwell Varco Pte Ltd., Mumbai vs. DCIT (International Taxation), Dehradun

In the result, captioned appeals of the Assessee in ITA No

ITA 1675/DEL/2016[2012-13]Status: DisposedITAT Dehradun27 Jan 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

DCIT O R D E R PER MANISH AGARWAL, AM: All the captioned appeals are filed by the assessee against the separate final assessment order of AO passed u/s 143(3)/144C(13) of the Income Tax Act, 1961 (“the Act” in short) subsequent to the direction of Ld. Dispute ... appeal raised by the assessee in all the Five assessment years. 7. In additional Ground of appeal, assessee is contending that the Final Assessment order passed for all the captioned assessment years by the A.O. are time barred by limitation and are bad in law, as they were passed beyond

ACIT, Circle-1(1)(1), Bangalore vs. Amazon Developement Centre(India) Private Limited, Bangalore

In the result, the appeal of the revenue for A

ITA 2127/BANG/2024[2012-13]Status: DisposedITAT Bangalore27 Jan 2026AY 2012-13

Bench: Ms. Padmavathy S & Shri Rahul Chaudhary

For Appellant: Ms. Deepashree Rao &For Respondent: Dr. Divya K.J, CIT-DR
Section 250

Graebel Relocation Services Worldwide Inc. Since the assessee chose to file appeal before the Ld.CIT(A), the assessing officer passed the final assessment order. The Ld.CIT(A) allowed the contention of the assessee with regard to inclusion and exclusions towards TP adjustments. The Ld.CIT(A) also deleted the disallowance made

DCIT, Circle-1(1)(1), Bangalore vs. Amazon Developement Centre (India) Private Limited, Bangalore

In the result, the appeal of the revenue for A

ITA 2036/BANG/2024[2013-14]Status: DisposedITAT Bangalore27 Jan 2026AY 2013-14

Bench: Ms. Padmavathy S & Shri Rahul Chaudhary

For Appellant: Ms. Deepashree Rao &For Respondent: Dr. Divya K.J, CIT-DR
Section 250

Graebel Relocation Services Worldwide Inc. Since the assessee chose to file appeal before the Ld.CIT(A), the assessing officer passed the final assessment order. The Ld.CIT(A) allowed the contention of the assessee with regard to inclusion and exclusions towards TP adjustments. The Ld.CIT(A) also deleted the disallowance made

Fort Canning Credit Investments Pte. Ltd., Singapore vs. Assistant Commissioner of Income-Tax (International Taxation) - 2(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2104/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2022-23 Fort Canning Investments Assistant Commissioner Of Pte. Ltd. Income-Tax (International 260 Orchard Road, #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aaccf9284G) (Appellant) (Respondent) Assessment Year: 2022-23 Fort Canning Credit Assistant Commissioner Of Investments Pte. Ltd. Income-Tax (International 260 Orchard Road #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aadcf7866R) (Appellant) (Respondent) Present For: Assessee : Shri Dhanesh Bafna, Ms. Priyanka Agarwala, Ms.Hirali Desai, Ms. Nidhi Agarwal & Shri Yogesh Malpani, Cas Revenue : Shri Satya Pal Kumar, Cit Dr & Shri Krishna Kumar, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 27.01.2026 Fort Canning Investments Pte. Ltd. & Fort Canning Credit Investments Pte. Ltd. Ay 2022-23

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Satya Pal Kumar, CIT DR and Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270A

objections filed by the assessee before the ld. DRP, the same were dismissed, endorsing the findings of ld. Assessing Officer, pursuant to which final assessment order was passed u/s. 144C(13) r.w.s. 143(3) making the additions as proposed in the draft assessment order. Aggrieved, assessee is in appeal before

Fort Canning Investments Pte. Ltd., Singapore vs. Assistant Commissioner of Income-Tax (International Taxation) - 2(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2103/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jan 2026AY 2022-23

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2022-23 Fort Canning Investments Assistant Commissioner Of Pte. Ltd. Income-Tax (International 260 Orchard Road, #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aaccf9284G) (Appellant) (Respondent) Assessment Year: 2022-23 Fort Canning Credit Assistant Commissioner Of Investments Pte. Ltd. Income-Tax (International 260 Orchard Road #14-02 Taxation) - 2(3)(1) Vs. The Heeren, Singapore, Mumbai Singapore – 238855 (Pan: Aadcf7866R) (Appellant) (Respondent) Present For: Assessee : Shri Dhanesh Bafna, Ms. Priyanka Agarwala, Ms.Hirali Desai, Ms. Nidhi Agarwal & Shri Yogesh Malpani, Cas Revenue : Shri Satya Pal Kumar, Cit Dr & Shri Krishna Kumar, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 27.01.2026 Fort Canning Investments Pte. Ltd. & Fort Canning Credit Investments Pte. Ltd. Ay 2022-23

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Satya Pal Kumar, CIT DR and Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270A

objections filed by the assessee before the ld. DRP, the same were dismissed, endorsing the findings of ld. Assessing Officer, pursuant to which final assessment order was passed u/s. 144C(13) r.w.s. 143(3) making the additions as proposed in the draft assessment order. Aggrieved, assessee is in appeal before

Camfil India Private Limited, Gurgaon vs. The Deputy Commissioner of Income Tax, Circle 1(1), Range 53, Gurgaon

ITA 6011/DEL/2024[2021-22]Status: DisposedITAT Delhi27 Jan 2026AY 2021-22

Bench: Shrivikas Awasthy & Shrisanjay Awasthi

Section 144CSection 144C(13)Section 153Section 92C

orders for the impugned assessment years are barred by limitation. It was the submission that for determining the period of limitation for passing final assessment order, the provisions of section 144C of the Act are to be read with section 153 of the Act, to the extent that the total ... individually furnished charts of relevant dates for the assessment years under consideration, for tabulating the relevant period of limitation within which the final assessment order was required to be passed. The Ld. ARs, in the individual cases being represented by them, demonstrated through the chart of dates that

Perfetti Van Melle India Pvt Lt.D, Gurgoan vs. DCIT, Circle-1, Gurgaon

In the result, appeal of the Assessee is allowed

ITA 5389/DEL/2024[2021-22]Status: DisposedITAT Delhi27 Jan 2026AY 2021-22

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(3)Section 153Section 153(1)Section 153(4)

Date of Hearing 22.01.2026 Date of Pronouncement 27.01.2026 ORDER PER MANISH AGARWAL, AM : The captioned appeal is filed by the Assessee, challenging the Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 [“the Act”] dated 29.10.2024 alongwith stay application filed ... taken reads as under: ITA No.5389/Del/2024 & SA No. 577/Del/2025 Perfetti Van Melle India Pvt. Ltd. Vs NFAC “Additional Ground No. 38: "That the Final Assessment Order dated 29.10.2024 passed under section 143(3) read with sections 144C(13) and 144B of the Income-tax Act, 1961 ("Act") by the National

Athena Hisar Solar Power Private Limited, New Delhi vs. DCIT Assessment Unit, Income Tax Department, Delhi

In the result, appeal of the Assessee is allowed

ITA 5372/DEL/2024[AY 2021-22]Status: DisposedITAT Delhi27 Jan 2026

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2021-22] Athena Hisar Solar Power Pvt. Vs Dcit, Assessment Unit, Ltd., J5/132, Rajouri Garden, Civic Centre, E-2, Delhi-110027 Delhi Pan-Aaoca5969P Appellant Respondent Assessee By Shri Salil Kapoor Adv. & Ms. Ananya Kapoor, Adv Revenue By Shri S.K. Jadhav, Cit Dr Date Of Hearing 19.01.2026 Date Of Pronouncement 27.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Assessee Challenging The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [“The Act”] Dated 26.09.2024 Pertaining To The Assessment Year 2021-22. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 26.09.2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee'S Representative Relying On The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Athena Hisar Solar Power Pvt. Ltd. Vs Dcit Roca Bathroom Products (P.) Ltd. [2022] 445 537 (Madras) & Also Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

Date of Hearing 19.01.2026 Date of Pronouncement 27.01.2026 ORDER PER MANISH AGARWAL, AM : The captioned appeal is filed by the Assessee challenging the Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 [“the Act”] dated 26.09.2024 pertaining to the Assessment Year ... Assessee raised Ground No. 2 contending that the Final Assessment order dated 26.09.2024 passed by the A.O. is time barred by limitation and is bad in law, as it has been passed beyond the time frame prescribed under section 153(1) read with section 153(4) of the Income

Johnson Matthey India Pvt. Ltd., Delhi vs. DCIT, Circle-13(1), Delhi

In the result, appeal of the Assessee is allowed

ITA 5199/DEL/2024[2021-22]Status: DisposedITAT Delhi27 Jan 2026AY 2021-22

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2021-22] Johnson Matthey India Pvt. Vs. Dcit, Ltd., 5Th Floor, C/O Regus Circle-13(1) Business Center, Gurgaon C.R. Building, Delhi Road, South West Delhi- 110037. Pan-Aaacj2919A Appellant Respondent Assessee By Shri Sumit Mangal, Adv. Ms. Radhika Sharma, Adv. Ms. Soumya Pandey, Adv. Revenue By Shri S.K. Jadhav, Cit Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Assessee Challenging The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [“The Act”] Dated 23.10.2024 Pertaining To The Assessment Year 2021-22. 2. During The Course Of Hearing The Bench Has Asked The Assessee To File Specific Ground Of Appeal No.2 As Against General Ground Of Appeal No. 2 Taken. In Compliance, Assessee Vide Application Dt. 12.03.2025 Filed Under Rule 11 Of The Income Tax Appellate Tribunal Rules, 1963 Raised Additional Ground Of Appeal Under. The Additional Ground Of Appeal Taken Reads As Under: Johnson Matthey India Pvt. Ltd. Vs. Dcit

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

Date of Hearing 22.01.2026 Date of Pronouncement 27.01.2026 ORDER PER MANISH AGARWAL, AM : The captioned appeal is filed by the Assessee challenging the Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 [“the Act”] dated 23.10.2024 pertaining to the Assessment Year ... First, we take additional Ground of appeal raised by the assessee. 5. In the additional ground of appeal, assessee contended that the Final Assessment order dated 23.10.2024 passed by the A.O. is time barred by limitation and is bad in law, as it has been passed beyond the time frame

Dora Medical Trading (India) Private Limited, Delhi vs. Assessment Unit, Income Tax Department

ITA 4998/DEL/2024[2021-22]Status: DisposedITAT Delhi27 Jan 2026AY 2021-22

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(3)Section 144BSection 144CSection 153Section 153(1)Section 153(4)

Date of Hearing 19.01.2026 Date of Pronouncement 27.01.2026 ORDER PER MANISH AGARWAL, AM : The captioned appeal is filed by the Assessee challenging the Final Assessment Order passed 143(3) r.w.s 144C(13) read with section 144B of the Income-tax Act of the Income Tax Act, 1961 [“the Act"] dated ... First, we take additional Ground of appeal raised by the assessee. 7. The Assessee raised additional ground of appeal contending that the Final Assessment order dated 30.09.2024 passed by the A.O. is time barred by limitation and is bad in law, as it has been passed beyond the time frame

Manlift India Private Limited, Delhi vs. Deputy Commissioner of Income Tax 16(3), New Delhi

ITA 4461/DEL/2024[2020-21]Status: DisposedITAT Delhi27 Jan 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(3)Section 144CSection 153Section 153(1)Section 153(4)

Negi Advs. Shri S.K.Jadhav, CIT DR 19.01.2026 27.01.2026 ORDER PER MANISH AGARWAL, AM : The captioned appeal is filed by the Assessee challenging the Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 [“the Act"] dated 29.07.2024 pertaining to the Assessment Year ... Assessee raised Ground of appeal No. 2 contending that the Final Assessment order dated 29.07.2024 passed by the A.O. is time barred by limitation and is bad in law, as it has been passed beyond the time frame prescribed under section 153(1) read with section

Delta Electronics India Private Limited, Gurgaon, Haryana vs. Assistant Commissioner of Income-Tax, Circle 1(1), Gurgaon, Haryana

ITA 4448/DEL/2024[2020-21]Status: DisposedITAT Delhi27 Jan 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(3)Section 144CSection 144C(13)Section 153Section 153(1)Section 153(4)

Kapoor, Adv Shri S.K. Jadhav, CIT DR 19.01.2026 27.01.2026 PER MANISH AGARWAL, AM : The captioned appeal is filed by the Assessee challenging the Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 [“the Act”] dated 31.07.2024 pertaining to the Assessment Year ... That, in view of the facts and circumstances of the case, the assessment proceedings qua the Appellant as well as the consequential final assessment order dated 31.07.2024 are illegal, bad in law, without jurisdiction and as such are barred by time limitation in view of Section

Mufg Bank, Ltd., New Delhi vs. Assistant Commissioner of Income-Tax, Circle 2(2)(1), Intl. Taxation, New Delhi

ITA 3929/DEL/2024[AY 2020-21]Status: DisposedITAT Delhi27 Jan 2026
Section 144CSection 144C(13)Section 153Section 92C

orders for the impugned assessment years, are barred by limitation. It was the submission that for determining the period of limitation for passing final assessment order, the provisions of section 144C of the Act are to be read with section 153 of the Act, to the extent that the total ... furnished a chart of relevant dates for the assessment years under consideration, for tabulating the relevant period of limitation within which the final assessment order was required to be passed. The Ld. AR demonstrated through the chart of dates that in all the assessment years the final assessment order