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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

Ariba India Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Delhi

In the result, appeal of the assessee is allowed

ITA 2705/DEL/2024[2011-12]Status: DisposedITAT Delhi27 Jan 2026AY 2011-12

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

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

Date of Pronouncement 27.01.2026 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the Assessee against the final assessment order dated 31.03.2024 passed u/s 144C r.w.s. 143(3) r.w.s. 254 of the Income Tax Act, 1961 (‘the Act”) arising out of the directions issued ... before the ld. DRP. The ld. DRP vide its order dated 30.11.2015 upheld the adjustments and additions proposed in draft assessment order. Accordingly, final assessment order u/s 144C(3) of the Act was passed on 29.01.2016 determining the total income of the assessee at Rs. 4,03,77,010/- after

Mufg Bank Ltd, New Delhi vs. ACIT, Circle 2(2)(1), International Taxation, New Delhi

ITA 134/DEL/2023[2019-20]Status: DisposedITAT Delhi27 Jan 2026AY 2019-20

Bench: Shri Vikas Awasthy & Shri Sanjay 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 ... 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

Mufg Bank Ltd. (Earlier Known As the Bank of Tokyo Mitsubishi Ufj, Ltd. ), New Delhi vs. ACIT Circle-2(2)(1), International Taxation, Delhi

ITA 1477/DEL/2022[2018-19]Status: DisposedITAT Delhi27 Jan 2026AY 2018-19

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthimufg Bank Ltd., आ.अ.सं/.I.T.A No. 134/Del/2023 निर्धारणवर्ष/Assessment Year: 2019-20 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. बनाम Vs. Acit, Circle 2(2)(1), International Taxation, Pan No.Aabct3880D E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant Assessee By प्रत्यर्थी/Respondent Shri Kshitij Bansal, Ca Revenue By Shri Dharm Veer Singh, Cit Dr Mufg Bank Ltd., आ.अ.सं/.I.T.A No.3929/Del/2024 निर्धारणवर्ष/Assessment Year: 2020-21 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. Pan No.Aabct3880D बनाम Vs. Acit, Circle 2(2)(1), International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Revenue By Shri Hiten Thakkar, Advocate (Virtual) Shri Dharm Veer Singh, Cit Dr Mufg Bank Ltd., बनाम 5Th Floor, Worldmark-2, Asset 8, Vs. आ.अ.सं/.I.T.A No.844/Del/2021 निर्धारणवर्ष/Assessment Year: 2016-17 Acit, Circle 2(2)(1), International Taxation, Aerocity, Nh-8, New Delhi. E-2 Block, Civic Centre, Pan No.Aabct3880D Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Revenue By Shri Kshitij Bansal, Ca Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.1476/Del/2022 निर्धारणवर्ष/Assessment Year: 2017-18 1

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

Mufg Bank Ltd. (Earlier Known As the Bank of Tokyo Mitsubishi Ufj, Ltd. ), Delhi vs. ACIT Circle-2(2)(1), International Taxation, New Delhi

ITA 1476/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Jan 2026AY 2017-18
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

Mufg Bank Ltd, New Delhi vs. ACIT, Circle-2(2)(1) (International Taxation), New Delhi

ITA 844/DEL/2021[2016-17]Status: DisposedITAT Delhi27 Jan 2026AY 2016-17

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No. 134/Del/2023 निर्धारणवर्ष/Assessment Year: 2019-20 Mufg Bank Ltd., 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. बनाम Vs. Acit, Circle 2(2)(1), International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. Pan No.Aabct3880D अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Shri Kshitij Bansal, Ca Revenue By Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.3929/Del/2024 निर्धारणवर्ष/Assessment Year: 2020-21 Mufg Bank Ltd., 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. Pan No.Aabct3880D बनाम Vs. Acit, Circle 2(2)(1), International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Shri Hiten Thakkar, Advocate (Virtual) Revenue By Shri Dharm Veer Singh, Cit Dr Mufg Bank Ltd., 5Th Floor, Worldmark-2, Asset 8, Aerocity, Nh-8, New Delhi. Pan No.Aabct3880D बनाम Vs. आ.अ.सं/.I.T.A No.844/Del/2021 निर्धारणवर्ष/Assessment Year: 2016-17 Acit, Circle 2(2)(1),International Taxation, E-2 Block, Civic Centre, Minto Road, New Delhi. अपीलार्थी Appellant प्रत्यर्थी/Respondent Assessee By Shri Kshitij Bansal, Ca Revenue By Shri Dharm Veer Singh, Cit Dr आ.अ.सं/.I.T.A No.1476/Del/2022 निर्धारणवर्ष/Assessment Year: 2017-18 1

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

Toshiba India Pvt. Ltd., Gurgaon vs. ACIT, Circle- 25(2), New Delhi

ITA 9752/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Jan 2026AY 2015-16

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

Aecom India Pvt. Ltd., Gurgaon vs. ACIT, Gurgaon

ITA 1021/DEL/2016[2011-12]Status: DisposedITAT Delhi27 Jan 2026AY 2011-12

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.2404/दिल्ली/2015 (नि.व. 2010-11)

For Respondent: S/Shri Vishal Kalra & Ankit Sahni, Advcoates with
Section 144CSection 144C(13)Section 153

assessment orders in the impugned assessment years are barred by limitation. He submitted 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. He furnished the date chart tabulating ... relevant dates for ascertaining the period of limitation within which the final assessment order was required to be passed and also the dates on which the final assessment orders for respective assessment years were actually passed by the Assessing Officer (AO). The Id. Counsel submits that various Benches

M/S. Aecom India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

ITA 2404/DEL/2015[2010-11]Status: DisposedITAT Delhi27 Jan 2026AY 2010-11

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.2404/दिल्ली/2015 (नि.व. 2010-11)

For Respondent: S/Shri Vishal Kalra & Ankit Sahni, Advcoates with
Section 144CSection 144C(13)Section 153

assessment orders in the impugned assessment years are barred by limitation. He submitted 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. He furnished the date chart tabulating ... relevant dates for ascertaining the period of limitation within which the final assessment order was required to be passed and also the dates on which the final assessment orders for respective assessment years were actually passed by the Assessing Officer (AO). The Id. Counsel submits that various Benches

Nobuhiro Watabe, Kancheepuram vs. DCIT, Ncw-17(3), Chennai

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

ITA 3179/CHNY/2025[2018-19]Status: DisposedITAT Chennai23 Jan 2026AY 2018-19

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3179/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 139(1)Section 142(1)Section 143(1)Section 250

present case. In the present case, the returns were filed without foreign tax credit, however the same was filed before passing of the final assessment order. The filing of foreign tax credit in terms of the rule 128 is only directory in nature. The rule is only for the implementation ... petitioner on February 2, 2021. The respondent is directed to give due credit to the Kenya income of the petitioner and pass the final assessment order. Further, it is made clear that the impugned order is set aside only to the extent of disallowing of foreign tax credit claim made

Incometax Officer, Chennai vs. Doosan Bobcat Private Limited, Chennai

In the result, the appeal of the Revenue is dismissed and the CO of assessee is dismissed as not-pressed

ITA 2288/CHNY/2025[2013]Status: DisposedITAT Chennai23 Jan 2026

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2288/Chny/2025 & C.O No.76/Chny/2025 (Arising In Ita No.2288/Chny/2025) िनधा%रण वष% /Assessment Year: 2013-14 The Income Tax Officer, Doosan Bobcat Pvt. Ltd., Htc Towers, 6Th Floor, Corporate Ward-2(1), Vs. Chennai. No.41, Gst Road, Guindy Industrial Estate S.O., Guindy, Chennai – 600 032. Pan: Aaccd 6529L

For Respondent: Mr. Praveen.S, JCIT
Section 250Section 32Section 32(1)(ii)

assessee to the tune of Rs. 1,76,08,007/-. The assessee preferred an appeal before the CIT(A) against the final assessment order passed by the A.O. the CIT(A) after considering the various submissions of the assessee allowed the grounds of appeal raised by the assessee

Manisha Devnani, Mumbai vs. Int Tax Ward2(1)(1) Mumbai, Mumbai

In the result, the appeal is rejected as non

ITA 344/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Jan 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2018-19

For Appellant: Mr. Varis Isani (Virtually appeared)For Respondent: 19/01/2026
Section 115BSection 144C(3)Section 147Section 56(2)(x)Section 69

consequently, Officer were treated as non est in the eye of law, and consequently, the Assessing Officer proceeded to pass the final assessment order the Assessing Officer proceeded to pass the final assessment order the Assessing Officer proceeded to pass the final assessment order under section 144C ... Appellate Tribunal lies only against a final tax Appellate Tribunal lies only against a final tax Appellate Tribunal lies only against a final assessment order passed pursuant to the directions of the Dispute assessment order passed pursuant to the directions of the Dispute assessment order passed pursuant to the directions

Bajaj Auto Limited, Mumbai vs. The Principal Commissioner of Income-Tax - 3, Mumbai

ITA 2666/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Jan 2026AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. P.J. Pardiwala a/wFor Respondent: Mr. Satyaprakash R. Singh, CIT-DR
Section 143(3)Section 144C(3)Section 145(2)Section 263Section 37(1)Section 40

Dispute Resolution Panel and intended to pursue the appellate remedy before the Commissioner (Appeals)/ National Faceless Appeal Centre, the Assessing Officer passed the final assessment order on 27.05.2022 under section 143(3) read with section 144C(3) of the Act. Aggrieved thereby, the assessee preferred an appeal before the National

DCIT(CC)-8(3), Mumbai vs. Shapoorji Palloni and Company Private Limited, Mumbai

Appeal of the assessee is allowed and grounds of appeal of Revenue are dismissed”

ITA 1217/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14
Section 143(3)Section 144C(3)Section 92Section 92B

Additional Ground of Appeal filed on 05/05/2025 2. The learned Commissioner of Income-tax (Appeals)-58 erred in not passing the final assessment order dated 07 February 2017 within the time limit prescribed under provision of Section 153 of the Act which provides the outer time limit for passing ... final assessment order and hence, the assessment proceeding is time barred and liable to be quashed. Additional supplementary ground of appeal filed on 18/09/2025 3. The learned Commissioner of Income-tax (Appeals)-58 erred in not allowing deduction under Section 35DD of the Act amounting to Rs.12

DCIT(CC)-8(3), Mumbai vs. Shapoorji Pallonji and Company Private Limited, Mumbai

ITA 1211/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13
For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

deleted. 3 Additional Ground of Appeal filed on 05/05/2025 2. The learned Commissioner of Income-tax (Appeals)-58 erred in not passing the final assessment order dated 07 February 2017 within the time limit prescribed under provision of Section 153 of the Act which provides the outer time limit ... passing the final assessment order and hence, the assessment proceeding is time barred and liable to be quashed. Additional supplementary ground of appeal filed on 18/09/2025 3. The learned Commissioner of Income-tax (Appeals)-58 erred in not allowing deduction under Section 35DD of the Act amounting to Rs.12

Shapoorji Pallonji and Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle -3(3)(1), Mumbai

Appeals are partly allowed

ITA 1150/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Additional Ground of Appeal filed on 05/05/2025 2. The learned Commissioner of Income-tax (Appeals)-58 erred in not passing the final assessment order dated 07 February 2017 within the time limit prescribed under provision of Section 153 of the Act which provides the outer time limit for passing ... final assessment order and hence, the assessment proceeding is time barred and liable to be quashed. Additional supplementary ground of appeal filed on 18/09/2025 3. The learned Commissioner of Income-tax (Appeals)-58 erred in not allowing deduction under Section 35DD of the Act amounting to Rs.12

Shapoorji Pallonji and Company Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 8(3), Mumbai

Appeals are partly allowed

ITA 1149/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Additional Ground of Appeal filed on 05/05/2025 2. The learned Commissioner of Income-tax (Appeals)-58 erred in not passing the final assessment order dated 07 February 2017 within the time limit prescribed under provision of Section 153 of the Act which provides the outer time limit for passing ... final assessment order and hence, the assessment proceeding is time barred and liable to be quashed. Additional supplementary ground of appeal filed on 18/09/2025 3. The learned Commissioner of Income-tax (Appeals)-58 erred in not allowing deduction under Section 35DD of the Act amounting to Rs.12

Haskoningdhv Consulting Private Limited, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, ITA No.1040/Del/2021 (Honda Cars India Ltd

ITA 6120/DEL/2024[2021-22]Status: DisposedITAT Delhi23 Jan 2026AY 2021-22

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.6120/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Haskoningdhv Consulting Private Limited Acit, Office No.204, 2Nd Floor, Rs Tower, Plot No. B Vs. Circle-10(1), 358A, New Ashok Nagar No.1267, Room No.389 A, 3Rd Floor, C.R. Building, Vasundhara Enclave, East Delhi. Pan No.Aaacm8966G Delhi. अपीलाथ" Appellant ""यथ"/Respondent

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

Lonza India Private Limited, Gurgaon vs. Deputy Commissioner of Income Tax, Circle 1(1), Gurgaon

ITA 6010/DEL/2024[2021-22]Status: DisposedITAT Delhi23 Jan 2026AY 2021-22

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.5351/दिल्ली/2024(नि.व. 2021-22)

Section 144CSection 144C(13)Section 153

hereinafter referred to as 'the Act'). The assessess in their respective appeals have raised the legal issue challenging validity of the final assessment order on the ground of limitation in the grounds of appeal. 3 ITA No.5351/Del/2024(A.Y 2021-22) ITA No.5763/Del/2024 (Α.Υ. 2021-22) ITA No. 6010/Del/2024 ... assessment orders in the impugned assessment years are barred by limitation. It is submitted 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. The Counsels furnished date chart

Fmi Automotive Components Private Limited, Manesar vs. Assessment Unit, Income Tax Department (Jao- DCIT/ACIT, Circle 7(1), New Delhi

ITA 5988/DEL/2024[2021-22]Status: DisposedITAT Delhi23 Jan 2026AY 2021-22

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

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

Hearing 21/01/2026 Date of Pronouncement 23/01/2026 ORDER PER YOGESH KUMAR, U.S. JM: The captioned appeals are filed by the Assessee challenging the Final Assessment Orders passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the Act in short) dated 26/07/2022 pertaining to the Assessment Year ... 26/06/2024 for A.Y 2020-21 and dated 30/10/2024 for Assessment Year 2021-22 respectively. 2. The Assessee raised Additional Ground contending that the Final Assessment orders dated 26/07/2022 pertaining to the Assessment Year 2018-19, dated 26/06/2024 for A.Y 2020-21 and dated 30/10/2024 for Assessment Year 2021-22 respectively

Iqr Analytics Pvt Ltd, Delhi vs. DCIT, Circle-10 (1), Delhi

ITA 5763/DEL/2024[2021-22]Status: DisposedITAT Delhi23 Jan 2026AY 2021-22

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.5351/दिल्ली/2024(नि.व. 2021-22)

Section 144CSection 144C(13)Section 153

hereinafter referred to as 'the Act'). The assessess in their respective appeals have raised the legal issue challenging validity of the final assessment order on the ground of limitation in the grounds of appeal. 3 ITA No.5351/Del/2024(A.Y 2021-22) ITA No.5763/Del/2024 (Α.Υ. 2021-22) ITA No. 6010/Del/2024 ... assessment orders in the impugned assessment years are barred by limitation. It is submitted 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. The Counsels furnished date chart