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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

Asst.C.I.T., Bangalore vs. M/S Astrazenca Pharma India Ltd., Bangalore

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 82/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Oct 2022AY 2010-11

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.82/Bang/2015 : Asst.Year 2010-2011 The Assistant Commissioner Of M/S.Astrazeneca Pharma India Limited, Ni 12Th Floor, Income-Tax, Large Tax Payers Unit V. Manyata Embassy Business, (Ltu) Rachenahalli, Outer Ring Road Bengaluru. Bangalore – 560 045. Pan : Aabca1722B. (Appellant) (Respondent) It(Tp)A No.170/Bang/2015 : Asst.Year 2010-2011 M/S.Astrazeneca Pharma India The Assistant Commissioner Limited, Ni 12Th Floor, Of Income-Tax, Large Tax V. Manyata Embassy Business, Payers Unit (Ltu) Bengaluru. Rachenahalli, Outer Ring Road Bangalore – 560 045. (Appellant) (Respondent) Revenue By : Sri.Manjunath Karkihalli, Cit-Dr Assessee By : Sri.Nageshwar Rao, Advocate Date Of Pronouncement : 14.10.2022 Date Of Hearing : 12.10.2022 O R D E R Per George George K, Jm : These Cross Appeals Are Directed Against Final Assessment Order Dated 31.12.2014 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2010- 2011. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Manufacture & Sale Of Pharmaceutical Products. It Also Undertakes Co- Ordination Of Clinical Trial Services. For The Assessment Year 2010-2011, The Return Of Income Was Filed Declaring Taxable

For Appellant: Sri.Nageshwar Rao, AdvocateFor Respondent: Sri.Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)Section 92C

Pronouncement : 14.10.2022 Date of Hearing : 12.10.2022 O R D E R Per George George K, JM : These cross appeals are directed against final assessment order dated 31.12.2014 passed u/s 143(3) r.w.s. 144C of the I.T.Act. The relevant assessment year is 2010- 2011. 2. The brief facts of the case ... namely, cost of sample distributed amounting to Rs.3,71,20,122 was also directed to be deleted. Pursuant to the DRP’s directions, final assessment order was completed vide the impugned order dated 31.12.2014. The computation of income as per the final assessment order is as under:- Computation of Income

Astrazeneca Pharma India Limited, Bangalore vs. Asst. C.I.T., Bangalore

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 170/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Oct 2022AY 2010-11

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.82/Bang/2015 : Asst.Year 2010-2011 The Assistant Commissioner Of M/S.Astrazeneca Pharma India Limited, Ni 12Th Floor, Income-Tax, Large Tax Payers Unit V. Manyata Embassy Business, (Ltu) Rachenahalli, Outer Ring Road Bengaluru. Bangalore – 560 045. Pan : Aabca1722B. (Appellant) (Respondent) It(Tp)A No.170/Bang/2015 : Asst.Year 2010-2011 M/S.Astrazeneca Pharma India The Assistant Commissioner Limited, Ni 12Th Floor, Of Income-Tax, Large Tax V. Manyata Embassy Business, Payers Unit (Ltu) Bengaluru. Rachenahalli, Outer Ring Road Bangalore – 560 045. (Appellant) (Respondent) Revenue By : Sri.Manjunath Karkihalli, Cit-Dr Assessee By : Sri.Nageshwar Rao, Advocate Date Of Pronouncement : 14.10.2022 Date Of Hearing : 12.10.2022 O R D E R Per George George K, Jm : These Cross Appeals Are Directed Against Final Assessment Order Dated 31.12.2014 Passed U/S 143(3) R.W.S. 144C Of The I.T.Act. The Relevant Assessment Year Is 2010- 2011. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In The Manufacture & Sale Of Pharmaceutical Products. It Also Undertakes Co- Ordination Of Clinical Trial Services. For The Assessment Year 2010-2011, The Return Of Income Was Filed Declaring Taxable

For Appellant: Sri.Nageshwar Rao, AdvocateFor Respondent: Sri.Manjunath Karkihalli, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 144C(11)Section 92C

Pronouncement : 14.10.2022 Date of Hearing : 12.10.2022 O R D E R Per George George K, JM : These cross appeals are directed against final assessment order dated 31.12.2014 passed u/s 143(3) r.w.s. 144C of the I.T.Act. The relevant assessment year is 2010- 2011. 2. The brief facts of the case ... namely, cost of sample distributed amounting to Rs.3,71,20,122 was also directed to be deleted. Pursuant to the DRP’s directions, final assessment order was completed vide the impugned order dated 31.12.2014. The computation of income as per the final assessment order is as under:- Computation of Income

Ntt Asia Pacific Holdings Pte. Ltd.(Formerly Known As Dimension Data Asia Pacific Pte. Ltd., Mumbai vs. ACIT (It)2(1)(2), Mumbai

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

ITA 325/MUM/2022[2018-19]Status: DisposedITAT Mumbai13 Oct 2022AY 2018-19

Bench: Shri Prashant Maharishi, Accountnat Member & Shri Sandeep Singh Karhail

For Appellant: Shri Sunil MotilalaFor Respondent: Shri Soumendu Kumar Dash
Section 115A(1)(a)Section 139(1)Section 143(3)Section 144CSection 144C(13)Section 194LSection 234ASection 234B

Order – 13/10/2022 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been filed by the assessee challenging the final assessment order dated 31/12/2021, passed under section 143(3) r/w section 144C(13) of the Income Tax Act, 1961 (‘the Act’), for the assessment year ... assessee, after noting that the material facts remain same during the year under consideration,. In conformity, the AO passed the impugned final assessment order dated 31/12/2021, under section 143(3) r/w section 144C(13) of the Act. Being aggrieved, the assessee is in appeal before us. NTT Asia Pacific Holdings

Infiniti Wholesale Ltd ( Formerly Knwon As Woolwonths Wholesale (India) P.Ltd), Mumbai vs. Asst CIT Cir 8(3), Mumbai

In the result, appeal filed by the Appellant is partly allowed

ITA 7718/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2022AY 2008-09
For Appellant: Shri Nitesh JoshiFor Respondent: Michael Jerald
Section 143(3)Section 144CSection 144C(5)Section 92C

during that year only. On the basis of the aforesaid direction issued by the DRP, the Assessing Officer passed the Final Assessment Order, dated 30.10.2012, computing the income of the Appellant as under: I Total income as per (-) 18,87,50,293 computation of income Add: Addition/disallowance as discussed above ... income (-) 10,68,91,995 5 Assessment Year: 2008-09 6. Being aggrieved, the Appellant is now in appeal before us challenging the Final Assessment Order, dated 30.10.2012, on the grounds reproduced in paragraph 2 above. We have heard the rival contention and perused the material on record including

M/S. Tivo Tech Private Limited (Formerly Known As Veveo (India) Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 237/BANG/2021[2016-17]Status: DisposedITAT Bangalore12 Oct 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 234BSection 37

Date of Pronouncement : 12.10.2022 O R D E R Per Padmavathy S., Accountant Member This appeal by the assessee company is against the final assessment order passed us/. 143(3) r.w.s. 144C(13) r.w.s. 143(3A) & 143(3B) of the Income-tax Act, 1961 [the Act] dated ... objections by the assessee, the DRP its directions dated 19.03.2021 rejected most of the objections. The AO passed the final assessment order dated 09.04.2021 pursuant to the DRP directions, whereby the TP adjustment was reworked to Rs. 4,52,45,728/- and the disallowance towards Rent, Legal and professional expenses

M/S Iqvia Ag (Previously Known As Ims Ag, Switzerland vs. The DCIT (Intl Tax) 2(2) 2, Mumbai

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

ITA 665/MUM/2022[2017-18]Status: DisposedITAT Mumbai10 Oct 2022AY 2017-18

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Iqvia Ag Dcit (It) – 2(2)(2) V. (Previously Known As Ims Ag) 16Th Floor, Air India Building C/O. Iqvia Consulting & Nariman Point Information Services India Pvt. Ltd., Mumbai – 400 021 Unit No. 902, 9Th Floor Supreme Business Park Hiranandani Gardens, Powai Mumbai - 400076 Pan: Aacci5872K Appellant Respondent Assessee By : Shri Madhur Agarwal Revenue By : Ms. Bharati Singh

For Appellant: Shri Madhur AgarwalFor Respondent: Ms. Bharati Singh
Section 144C(5)Section 90(2)

r.w.s 144C(13) of the Act. Therefore, certain informations were not available with him at the time of completion of the final Assessment Order. However, assessee has filed rectification application u/s. 154 of the Act and it is the duty imposed on the Assessing Officer to complete the rectification process

B Braun Medical (India ) Pvt. Ltd, Mumbai vs. DCIT -1(2) (1), Mumbai

ITA 454/MUM/2022[2017-18]Status: DisposedITAT Mumbai10 Oct 2022AY 2017-18
Section 143(3)Section 144C(15)(B)Section 144C(15)(b)Section 144C(2)Section 92C

with the Dispute Resolution Panel-1 Mumbai (the ‘DRP’) on 20-04-2021. After receipt of direction from Ld. DRP, the AO passed final assessment order dated 28-01-2022 under section 143(3) r.w. 144C(13) r.w.s. 144B of the Income-Tax Act. The Ground ... Income-Tax Act and that the Ld. AO ought not to have passed the draft assessment order u/s 144C(2) and the final assessment order u/s 143(3) of the IT Act.. It is observed that the Ld. AO has referred the assessee’s case under section 92CA

Csav Group (India) Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

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

ITA 1941/DEL/2015[2010-11]Status: DisposedITAT Mumbai10 Oct 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Rajan R. VoraFor Respondent: Ms. Samruddhi D. Hande
Section 143(3)Section 144CSection 234BSection 271(1)(c)Section 92CSection 92D

10/10/2022 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 30/01/2015, passed under section 143(3) r/w section 144C of the Income Tax Act, 1961 („the Act‟), for the assessment year ... length margin to 29.42% and transfer pricing adjustment to Rs 2,50,95,808. However, the AO passed the impugned final assessment order dated 30/01/2015 under section 143 (3)/144C of the Act without correctly incorporating the transfer pricing adjustment pursuant to learned DRP‟s directions. Being aggrieved, the assessee

Softlayer Technologies India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

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

ITA 265/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Oct 2022AY 2016-17

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)
Section 143(3)Section 92C

accepted for inclusion of Microland Ltd. as comparable. The DRP after considering the detailed submissions, passed order on 22/03/2020 and accordingly the final assessment order was passed by the AO on 24/04/2021 after making TP adjustment of Rs.10,82,52,229/-. IT(TP)A No.265/Bang/2021 Page ... Aggrieved from the final assessment order, the assessee filed appeal before the ITAT. 6. The ld.AR reiterated the submissions made before the lower authorities and he has also filed chart in respect of additional comparables proposed by the assessee for inclusion and exclusionsadn argued his case vehemetnly . He also filed

Wipro Ge Healthcare Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal filed by the assessee in IT(TP)A No

ITA 703/BANG/2021[2012-13]Status: DisposedITAT Bangalore07 Oct 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri K.R. Pradeep &For Respondent: Shri Praveen Karanth, D.R
Section 143(3)Section 254Section 92C

remove Kals Information Systems Ltd (seg) as a comparable. 2.8 Pursuant to the directions of the DRP, the AO passed the final assessment order u/s 143(3) r.w.s. 254 r.w.s. 144C(1) on 29.05.2021 retaining the addition of Rs. 2,42,58,140/- as per draft assessment order ignoring ... dissimilarity. Relevant portion from DRP directions is extracted as under: 9.2 However, the AO/TPO did not give effect to the same in the final assessment order. There is no appeal by the department against the direction of the DRP. Hence Ld. A.R. requested that the same be removed from

Wipro Ge Healthcare Private Limited (Earlier Known As Ge Medical Systems India Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal filed by the assessee in IT(TP)A No

ITA 344/BANG/2021[2006-07]Status: DisposedITAT Bangalore07 Oct 2022AY 2006-07

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri K.R. Pradeep &For Respondent: Shri Praveen Karanth, D.R
Section 143(3)Section 254Section 92C

remove Kals Information Systems Ltd (seg) as a comparable. 2.8 Pursuant to the directions of the DRP, the AO passed the final assessment order u/s 143(3) r.w.s. 254 r.w.s. 144C(1) on 29.05.2021 retaining the addition of Rs. 2,42,58,140/- as per draft assessment order ignoring ... dissimilarity. Relevant portion from DRP directions is extracted as under: 9.2 However, the AO/TPO did not give effect to the same in the final assessment order. There is no appeal by the department against the direction of the DRP. Hence Ld. A.R. requested that the same be removed from

Asst CIT Cir 2(2)(1), Mumbai vs. Mahindra & Mahindra Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1739/MUM/2015[2010-11]Status: DisposedITAT Mumbai04 Oct 2022AY 2010-11

Bench: Shri M. Balaganesh () & Smt. Kavitha Rajagopal () Mahindra & Mahindra Limited Vs Asst.Commissioner Of Income-Tax, Corporation Taxation, P.K. Kurne Circle-2(2)(1), Mumbai Chowk, Worli, Mumbai-400 018 Aayakar Bhavan, M.K. Road Pan : Aaacm3025E Mumbai-400 020 Appellant Respondent Asst.Commissioner Of Income-Tax, Vs 020Mahindra & Mahindra Limited Circle-2(2)(1), Mumbai Corporation Taxation, P.K. Kurne Aayakar Bhavan, M.K. Road Chowk, Worli, Mumbai-400 018 Mumbai-400 Pan : Aaacm3025E Appellant Respondent

Section 143(3)Section 144CSection 14ASection 35Section 40Section 80I

Kavitha Rajagopal (JM): These are cross appeals filed by the assessee and the revenue as against the final assessement order dated 30/01/2015 passed by the Assessing Officer 2 ITA 1676/Mum/2015 ITA 1739/Mum/2015 pursuant to the direction of the Ld. Dispute Resolution Panel (DRP) under section 144C (5) of the income ... disallowance under section 80IC and octroi incentive thereby proposing to assess the income at Rs. 25,07, 36,09,270/-. Aggrieved by the final assessment order both the assessee and the revenue appeal before us on various grounds mentioned herein after. 3 ITA 1676/Mum/2015 ITA 1739/Mum/2015 3. This appeal filed

Mahindra & Mahindra Limited, Mumbai vs. ACIT, Cir -2(2)(1), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1676/MUM/2015[2010-11]Status: DisposedITAT Mumbai04 Oct 2022AY 2010-11

Bench: Shri M. Balaganesh () & Smt. Kavitha Rajagopal () Mahindra & Mahindra Limited Vs Asst.Commissioner Of Income-Tax, Corporation Taxation, P.K. Kurne Circle-2(2)(1), Mumbai Chowk, Worli, Mumbai-400 018 Aayakar Bhavan, M.K. Road Pan : Aaacm3025E Mumbai-400 020 Appellant Respondent Asst.Commissioner Of Income-Tax, Vs 020Mahindra & Mahindra Limited Circle-2(2)(1), Mumbai Corporation Taxation, P.K. Kurne Aayakar Bhavan, M.K. Road Chowk, Worli, Mumbai-400 018 Mumbai-400 Pan : Aaacm3025E Appellant Respondent

Section 143(3)Section 144CSection 14ASection 35Section 40Section 80I

Kavitha Rajagopal (JM): These are cross appeals filed by the assessee and the revenue as against the final assessement order dated 30/01/2015 passed by the Assessing Officer 2 ITA 1676/Mum/2015 ITA 1739/Mum/2015 pursuant to the direction of the Ld. Dispute Resolution Panel (DRP) under section 144C (5) of the income ... disallowance under section 80IC and octroi incentive thereby proposing to assess the income at Rs. 25,07, 36,09,270/-. Aggrieved by the final assessment order both the assessee and the revenue appeal before us on various grounds mentioned herein after. 3 ITA 1676/Mum/2015 ITA 1739/Mum/2015 3. This appeal filed

Mwh India P.Ltd, Mumbai vs. DCIT Cir 9(2), Mumbai

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 1891/MUM/2014[2009-10]Status: DisposedITAT Mumbai03 Oct 2022AY 2009-10

Bench: Vikas Awasthy & Shri Prashant Maharishiआअसं. 1891/मुं/2014 ("न. व. 2009-10 ) Mwh India Pvt. Ltd. 168, Udyog Bhavan, Sonawala Road, Goregaon(E) Mumbai 400 063. Pan: Aaaca-4613-L ...... अपीलाथ" /Appellant बनाम Vs. The Dy.Commissioner Of Income Tax, Circle – 9(2), Aaykar Bhavan, M.K.Road, Mumbai 400 020 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Jehangir D.Mistri With Shri Ketan Ved & Shri Niraj Sheth ""तवाद" "वारा/Respondent By : Ms. Vatsalaa Jha सुनवाई क" "त"थ/ Date Of Hearing : 08/07/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 03/10/2022 आदेश/ Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 31/01/2014 Passed U/S 143(3) R.W.S. 144C (13) Of The Income Tax Act, 1961 [In Short ‘The Act’]

For Appellant: Shri Jehangir D.Mistri with Shri Ketan Ved & Shri Niraj ShethFor Respondent: Ms. Vatsalaa Jha
Section 10ASection 143(3)Section 50BSection 92C

respectively. Though before the DRP the assessee was not successful on the aforesaid adjustments , however, the Assessing Officer while passing the final assessment order made no addition. The solitary addition in respect t of adjustment made by Assessing Officer was Rs.34,75,99,943/- on account of slump sale ... have been raised out of abundant caution as the TPO and DRP has proposed the adjustment although the Assessing Officer in the final assessment order has made no such addition. Hence, the adjustments made by the TPO/DRP cannot be given effect. In support of his contentions the ld.Counsel

Hewlett Packard (India) Software Operation Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 413/BANG/2022[2017-18]Status: DisposedITAT Bangalore03 Oct 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.413/Bang/2022 Assessment Year: 2017-18

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 192Section 195Section 37Section 40Section 92C

Date of Pronouncement : 03.10.2022 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by the assessee is directed against the final assessment order passed by the Deputy Commissioner of Income- tax, TP Circle-1(3)(1) dated 28.01.2021 u/s 92CA(3) of the Income

Ntt Data Fa Insurance Systems (India) Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 261/BANG/2021[2016-17]Status: DisposedITAT Bangalore03 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.261/Bang/2021 Assessment Year: 2016-17

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 143(3)Section 92C

Hearing : 22.09.2022 Date of Pronouncement : 03.10.2022 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is directed against final assessment order passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (for short “the Act”) dated 27.4.2021. The assessee has raised following ... Insurance Systems (India) Pvt. Ltd., Bangalore Page 5 of 37 3.2 Pursuant to the directions of the Ld. DRP, the AO passed the final assessment order dated 27.04.2021 in line with the directions issued by Ld. DRP. Aggrieved by the final assessment order, the assessee has preferred the above appeal

Hewlett Packard (India) Software Operation Private Limited, 2016-17 vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 213/BANG/2021[2016-17]Status: DisposedITAT Bangalore03 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.213/Bang/2021 Assessment Year: 2016-17

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Capt. Pradeep Arya, D.R
Section 133(6)Section 143(3)Section 92C

Date of Pronouncement : 03.10.2022 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by the assessee is directed against the final assessment order passed by the Deputy Commissioner of Income- tax, Circle-3(1)(1) dated 31.3.2021 u/s 143(3) r.w.s. 144C(13) and 144C(13) r.w.s.143

M/S. Mahindra Homes Pvt. Ltd, Mumbai vs. Addl/Jt/Dy/ACIT/ITO/NFAC, Mumbai

In the result, the appeal of the assessee for Asst Year 2016-17 is partly allowed for statistical purposes

ITA 2179/MUM/2021[2017-18]Status: DisposedITAT Mumbai30 Sept 2022AY 2017-18

Bench: Us That The Issues In Asst Year 2016-17 May Be Taken As The Lead Case & The Decision Rendered Thereon Would Apply With Equal Force For The Asst Year 2017-18 Also In View Of Identical Facts Except With Variance In Figures.

Section 143(3)Section 144C(13)Section 144C(5)Section 92C

30/09/2022 आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.2179/Mum/2021 & 1008/Mum/2021 preferred by the order against the final assessment order passed by the Assessing Officer u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant to the directions ... balance amount of Rs 1,43,479/- is allowed to be carried forward. However, in the computation sheet accompanying the final assessment order passed by the ld.AO pursuant to be directions issued by ld. DRP, the ld. AO had failed to grant credit for the said unabsorbed depreciation brought forward

Mahindra Homes P. Ltd., Mumbai vs. ITO, Range-7(2)(1), Mumbai

In the result, the appeal of the assessee for Asst Year 2016-17 is partly allowed for statistical purposes

ITA 1008/MUM/2021[2016-17]Status: DisposedITAT Mumbai30 Sept 2022AY 2016-17

Bench: Us That The Issues In Asst Year 2016-17 May Be Taken As The Lead Case & The Decision Rendered Thereon Would Apply With Equal Force For The Asst Year 2017-18 Also In View Of Identical Facts Except With Variance In Figures.

Section 143(3)Section 144C(13)Section 144C(5)Section 92C

30/09/2022 आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.2179/Mum/2021 & 1008/Mum/2021 preferred by the order against the final assessment order passed by the Assessing Officer u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant to the directions ... balance amount of Rs 1,43,479/- is allowed to be carried forward. However, in the computation sheet accompanying the final assessment order passed by the ld.AO pursuant to be directions issued by ld. DRP, the ld. AO had failed to grant credit for the said unabsorbed depreciation brought forward

American Chemical Society, Gurgaon vs. The Asstt. CIT (International Taxation)-1(3)(2), Mumbai

In the result, appeal by the assessee is allowed for statistical purpose

ITA 1521/MUM/2022[2018-19]Status: DisposedITAT Mumbai29 Sept 2022AY 2018-19

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Vishal KalraFor Respondent: Shri S.H. Usmani
Section 143(3)Section 144C(13)Section 253(1)(d)Section 9(1)(vi)

Order – 29/09/2022 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present appeals have been filed by the assessee challenging separate final assessment orders of even date 20/04/2022, passed under section 143(3) r/w section 144C(13) of the Income Tax Act, 1961 (“the Act”) for the assessment ... assessment years 2014–15 to 2016– 17, rejected the objections filed by the assessee. In conformity, the Assessing Officer passed impugned final assessment order dated 20/04/2022. Being aggrieved, the assessee is in appeal before us. American Chemical Society ITA Nos. 1521/Mum./2022 and 1520/Mum./2022 10. During the course