“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

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

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

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

DCIT, Cir-6(2)(2), Mumbai vs. Diageo India Pvt.Ltd., Mumbai

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

ITA 2858/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aaaci 3378 L Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR

Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

wholly and exclusively for the purposes of its business. 033. The objection before the learned dispute resolution panel was dismissed. Therefore, in the final assessment order such addition was made. 034. The learned authorised representative submitted that this issue arose in the case of the assessee for assessment year

Diageo India P.Ltd, Mumbai vs. DCIT RG 6(2)(2), Mumbai

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

ITA 1002/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR

Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

Citrix R & D India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result, the appeal filed by the assessee stands allowed partly as indicated herein above

ITA 220/BANG/2021[2016-17`]Status: DisposedITAT Bangalore25 Aug 2022

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 220/Bang/2021 Assessment Year : 2016-17 M/S. Citrix R&D India Pvt. Ltd., The Deputy Prestige Dynasty, Commissioner Of Ground Floor, Income Tax, 33/2, Ulsoor Road, Circle – 2(1)(1), Bangalore – 560042. Vs. Bangalore. Pan: Aabcn3639C Appellant Respondent Assessee By : Shri Sumit Khurana, Ca Revenue By : Shri M. Mathivanan, Cit-Dr Date Of Hearing : 04-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Assessment Order Dated 30/03/2021 Passed By The National E-Assessment Centre, Delhi Relating To Assessment Year 2016-17 On Following Grounds Of Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another. 1. That The Order Passed By The Learned Ao To The Extent Prejudicial To The Appellant, Is Bad In Law & Liable To Be Quashed. Transfer Pricing - 2. That The National E-Assessment Centre, Delhi / Deputy Commissioner Of Income Tax, Circle 2(1)(1), Bangalore ("Assessing Officer" Or "Learned Ao") & The Dispute Resolution Panel - 1 ("Learned Panel" Or "Learned Drp")

For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri M. Mathivanan, CIT-DR

Rs.59,94,72,979/-. The corporate tax addition proposed in the draft assessment order was also confirmed by the Ld.AO in the final assessment order. Page 11 of 53 IT(TP)A No. 220/Bang/2021 Aggrieved by the final assessment order, the assessee filed present appeal before this Tribunal

M/S Infineon Technologies India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

ITA 3355/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 3355/Bang/2018 Assessment Year : 2014-15 M/S. Infineon Technologies India Pvt. The Deputy Ltd., Commissioner Of 9Th Floor, Prestige Income Tax, Thirulakshmi, Circle – 3(1)(1), No. 11, Mg Road, Vs. Bangalore. Bangalore. Pan: Aabcs6967N Appellant Respondent : Shri K.R. Vasudevan, Assessee By Advocate : Shri Sumer Singh Meena, Revenue By Cit Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 26/10/2018 By The Ld.Dcit, Circle – 3(1)(1), Bangalore On Following Grounds Of Appeal: “A. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp') Grossly Erred In Adjusting The Transfer Price By Inr 9,56,93,721/- With Respect To The International

For Respondent: Shri K.R. Vasudevan

Section 92C

Excess depreciation – 11,25,986 Page 10 of 29 IT(TP)A No. 3355/Bang/2018 2.11 Aggrieved by the final assessment order, assessee is in appeal before this Tribunal. 3. At the outset, the Ld.AR submitted that Ground nos. 1 to 13 are general in nature and therefore do not require

M/S Praxair India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Ltpu Circle-1, Bangalore

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

ITA 2839/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 Aug 2022AY 2013-14

For Appellant: Sri.T.Suryanarayana, Senior AdvocateFor Respondent: Sri.Bijoy Kumar Panda, CIT-DR

Section 143(2)Section 143(3)Section 14ASection 37

Hearing : 26.07.2022 O R D E R Per George George K, JM : This appeal at the instance of the assessee is directed against final assessment order dated 30.10.2017 passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant assessment year is 2013-2014. 2. The brief facts ... Resolution Panel (DRP). The DRP vide its directions dated 18.09.2017, largely confirmed the draft assessment order. Pursuant to the DRP’s directions, the final assessment order was passed on 31.10.2017. 5. Aggrieved by the final assessment order, the assessee has filed the present appeal before the Tribunal. The issues raised

Oocl Logistics (India) P.Ltd, Mumbai vs. ITO 7(3)(1), Mumbai

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

ITA 2001/MUM/2015[2010-11]Status: DisposedITAT Mumbai24 Aug 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Siddhesh ChauguleFor Respondent: Ms. Vatsalaa Jha

Section 143(3)Section 144C(13)Section 234BSection 244A

24/08/2022 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 04/02/2015, passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 („the Act‟), for the assessment year ... Therefore, the TPO proposed no change in computation of benchmarking PLI as well as the adjustment. In conformity, the AO passed the impugned final assessment order under section 143(3) read with section 144C (13) of the Act. Being aggrieved, assessee is in appeal before us. 11. During the course

M/S. Rittal India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 392/BANG/2022[2017-18]Status: DisposedITAT Bangalore24 Aug 2022AY 2017-18

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

For Appellant: Shri Ramasubramaniyan, CAFor Respondent: Shri Bijoy Kumar Panda, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 37Section 92Section 92C

deduction by the assessee. The DRP confirmed the TP adjustment as well as the disallowance made by the AO. The AO passed the final assessment order against which assessee is in appeal before the Tribunal. Notional interest on receivables 4. During the course of TP proceedings the AO treated

Safran Engineering Services India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circe-6(1)(1), Bangalore

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

ITA 297/BANG/2022[2017-18]Status: DisposedITAT Bangalore24 Aug 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Bijoy Kumar Panda, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 92C

receivable due to which the TP adjustment was enhanced to Rs.69,07,390 towards interest on delayed receivables. The AO passed the final assessment order accordingly. Aggrieved, the assessee is in appeal before the Tribunal. 4. The assessee has raised 18 grounds with regard to the ALP adjustment in respect

M/S. Nike India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 203/BANG/2021[2016-17]Status: DisposedITAT Bangalore24 Aug 2022AY 2016-17

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.203/Bang/2021 : Asst.Year 2016-2017 M/S.Nike India Private Limited The Deputy Commissioner Of Ground & First Floor, Olympia Income-Tax, Circle 3(1)(1) V. Bangalore. Building, No.66/1, Begmane Tech Park, C.V.Raman Nagar Bangalore – 560 093. Pan : Aabcn9612K. (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Bijoy Kumar Panda, Cit-Dr Date Of Pronouncement : 24.08.2022 Date Of Hearing : 23.08.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 27.03.2021 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2016-2017. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Wholesale Distributor Of Nike Brand Products In India. For The Assessment Year 2016-2017, The Return Of Income Was Filed On 30.11.2016 Declaring Total Loss Of Rs.164,42,63,191. The Assessment Was Selected For Scrutiny & Notice U/S 143(2) Of The I.T.Act Was Served. During The Course Of Assessment Proceedings, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The 2 It(Tp)A No.203/Bang/2021. M/S.Nike India Private Limited. Arm’S Length Price (Alp) Of The International Transaction Undertaken By The Assessee With Its Associate Enterprises (Aes). The Tpo Vide Order Dated 31.10.2019, Passed U/S 92Ca Of The I.T.Act, Proposed The Tp Adjustment Totaling To Rs.63,27,41,494 Under Various Segments. The Details Of The Same Are As Follows:- Segment Adjustment (Rs.) Issue Of Sourcing Commission 30,57,35,722 Reimbursement Of Expenses 17,77,95,683 Third Party Royalty 2,00,08,967 Amp Expenses 12,92,01,122 Total 63,27,41,494

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Bijoy Kumar Panda, CIT-DR

Section 143(2)Section 143(3)Section 92C

Hearing : 23.08.2022 O R D E R Per George George K, JM : This appeal at the instance of the assessee is directed against final assessment order dated 27.03.2021 passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant assessment year is 2016-2017. 2. The brief facts ... objections raised by the assessee. The DRP partially granted relief to the assessee. Pursuant to the draft assessment order, the impugned final assessment order was passed on 27.03.2021. 5. Aggrieved, the assessee has filed the present appeal before the Tribunal. Both the parties agreed that revised grounds submitted

M/S Information Technology Park Limited, Bangalore vs. Income Tax Officer Ward-11(2), Bangalore

ITA 1358/BANG/2018[2010-11]Status: DisposedITAT Bangalore24 Aug 2022AY 2010-11

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Rajesh Kumar Jha, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 143(2)Section 143(3)Section 2(22)

that arose out of the difference between the redemption value adopted by the assessee and the TPO. The AO passed the final assessment order giving effect to the TP adjustment based on the letter filed by the assessee that the assessee would not be filing objections before

M/S Information Technology Park Limited, Bangalore vs. Income Tax Officer Ward-3(1)(4), Bangalore

ITA 1357/BANG/2018[2009-10]Status: DisposedITAT Bangalore24 Aug 2022AY 2009-10

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Rajesh Kumar Jha, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 143(2)Section 143(3)Section 2(22)

Orient Overseas Container Line Limited, Mumbai vs. Office of the Deputy Commissioner of Income Tax (International Tax)-3(2)(2), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 826/MUM/2022[2018-19]Status: DisposedITAT Mumbai23 Aug 2022AY 2018-19

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleorient Overseas Container Line Limited V. Dcit(It)-3(2)(2) C/O. Oocl (India) Private Limited 16Th Floor Icc Chambers, 5Th Floor Air India Building Saki Vihar Road, Opp. Santogen Silk Mills Nariman Point Powai, Mumbai - 400072 Mumbai – 400 021 Pan: Aaaco5679E (Appellant) (Respondent) Assessee By : Shri Nikhil Tiwari Department By : Ms. Bharati Singh

For Appellant: Shri Nikhil TiwariFor Respondent: Ms. Bharati Singh

Section 143(2)Section 143(3)Section 144C(5)Section 154Section 234CSection 44B

issue of adding service tax and GST for computation of the presumptive taxation in favour of the assessee. Accordingly, Assessing Officer completed the final Assessment Order by considering the gross total income at ₹.76,36,71,291/- and determined the gross tax payable on total income ... return of income (copy of ITR-V is enclosed as Annexure 4). However, in the computation sheet attached with the above final assessment order, TDS credit was restricted to Rs. 1,38,91,173 which has resulted in a short credit of Rs. 4,35,455. 1.2 In this regard

Wns Global; Services Pvt Ltd., Mumbai vs. Dy CIT Circle- 14 (3)(1), Mumbai

In the result appeal filed by the assessee is partly allowed

ITA 295/MUM/2020[2015-16]Status: DisposedITAT Mumbai23 Aug 2022AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Cross Objection No. 52/Mum/2020 (Arising In Ita No. 2383/Mum/2019 For A.Y. 10-11)

For Appellant: ShriFor Respondent: Shri Tejandra Pal Singh, DR

income-tax return of Rs. 3,78,55,73,760. 2. erred in passing a draft assessment order in lieu of the final assessment order without considering that the Appellant is an Indian company in whose case the transfer pricing order passed under Section 92CA ... A.Ys. 15-16, 10-11 the Appellant during the subject AY and accordingly, the draft assessment order is void ab initio and the final assessment order dated 23 October 2019 (received on 13 November 2019) passed in the case of the Appellant is time barred; Transfer Pricing Grounds 3. erred

DCIT-14(3)(1), Mumbai vs. Wns Global Services Pvt Ltd., Mumbai

In the result appeal filed by the assessee is partly allowed

ITA 2383/MUM/2019[2010-11]Status: DisposedITAT Mumbai23 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Cross Objection No. 52/Mum/2020 (Arising In Ita No. 2383/Mum/2019 For A.Y. 10-11)

For Appellant: ShriFor Respondent: Shri Tejandra Pal Singh, DR

Oocl Logistics (India ). P.Ltd, Mumbai vs. DCIT Cir 7(1), Mumbai

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

ITA 7024/MUM/2012[2008-09]Status: DisposedITAT Mumbai23 Aug 2022AY 2008-09

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ajit Jain a/wFor Respondent: Ms. Vatsalaa Jha

Section 115JSection 143(3)Section 144CSection 234DSection 271(1)(C)Section 271(1)(c)Section 92C(2)Section 92C(3)Section 92D

23/08/2022 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 20/09/2012, passed under section 143(3) read with section 144C (13) of the Income Tax Act, 1961 („the Act‟), for the assessment year ... 26/07/2012, issued under section 144C(5) of the Act dismissed the objections filed by the assessee. In conformity, the AO passed the impugned final assessment order under section 143(3) read with section 144C(13) of the Act. Being aggrieved, assessee is in appeal before us. 9. During the course

Immarsat Global Ltd., Mumbai vs. DCIT (It) 2(2)(1), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose and ground raised by the assessee are allowed for statistical purpose

ITA 626/MUM/2022[2018-19]Status: HeardITAT Mumbai22 Aug 2022AY 2018-19

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleinmarsat Global Limited V. Dcit (It) – 2(2)(1) Ernst & Young Llp Room No. 1722, 17Th Floor 14Th Floor, The Ruby Air India Building, Nariman Point 29 Senapati Bapat Marg Mumbai – 400021 Dadar (W), Mumbai – 400028 Pan: Aaaci6098K (Appellant) (Respondent) Assessee By : Ms. Aarati Sathe Department By : Ms. Bharati Singh

For Appellant: Ms. Aarati SatheFor Respondent: Ms. Bharati Singh

Section 143(2)Section 144C(5)

detailed submissions rejected the objections Nos. 1 to 7 made by the assessee. Accordingly, Assessing 11 Inmarsat Global Limited Officer passed the final Assessment Order sustaining the additions made by the Assessing Officer in the draft Assessment Order. 6. Aggrieved assessee is in appeal before us raising following grounds

Damco International Bv, Mumbai vs. Deputy Commissioner of Income Tax (It)-2(1)(2), Mumbai

In the result, appeal by the assessee is partly allowed

ITA 7447/MUM/2017[2013-14]Status: DisposedITAT Mumbai22 Aug 2022AY 2013-14

For Appellant: Shri Poras Kaka, Sr.Advocate with Shri Manish KanthFor Respondent: S/ Shri B.K.Bagchi & Milind Chavan

Section 143(3)Section 234ASection 244ASection 271(1)(c)Section 92C

Damco India as per the Network agreement . In the assessment order for assessment year 2013-14 the Assessing Officer while passing the final assessment order reiterated the 9 observations made by the DRP. The Assessing Officer has made no observation that the facts or the agreement in the impugned assessment

Eit Services India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

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

ITA 210/BANG/2021[2016-17]Status: DisposedITAT Bangalore22 Aug 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Praveen Karanth, D.R

Section 133(6)Section 143(3)Section 92D

claimed as a deduction by the Appellant while filing its return of income. 12. That in the computation sheet annexed to the final assessment order, the AO erroneously considered the total income at Rs 1271,74,65,420/- as against Rs. 1269,72,60,217/- computed in the final assessment ... order. 13. That in the final assessment order the AO erroneously adopted the TP adjustment at Rs. 339.44,00.000/- against Rs 310,47,31.000/- as computed in the order passed by the TPO giving effect to the DRP's directions. IT(TP)A No.210/Bang/2021 EIT Services India Pvt. Ltd., Bangalore

Capita India Pvt Limited (Capita India), Mumbai vs. Nafc Delhi, Delhi

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

ITA 732/MUM/2022[2017-18]Status: DisposedITAT Mumbai18 Aug 2022AY 2017-18

Section 143(3)Section 14A

Hearing 29.06.2022 Date of Pronouncement 18.08.2022 O R D E R Per B.R.Baskaran (AM) :- The assessee has filed this appeal challenging the final assessment order dated 25-02-2022 passed by the assessing officer, National faceless assessment centre, Delhi for assessment year 2017-18 u/s 143(3) r.w.s 144C ... transfer pricing adjustment of Rs.55,55,86,006/-. The assessee did not get relief before Ld DRP and hence the AO passed the final assessment order making addition of above said amount as transfer pricing adjustment. 6. The assessee has raised many grounds with regard to many comparable companies. However

Zodiac Maritime Agencies India P. Ld., Mumbai vs. National E-Assesment Centre (Neac), Delhi

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

ITA 1225/MUM/2021[2016-17]Status: DisposedITAT Mumbai18 Aug 2022AY 2016-17

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Anil SatheFor Respondent: Shri Tejinder Pal Singh Anand

Section 143(3)Section 144BSection 144C(13)Section 234Section 234BSection 92C

18/08/2022 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 27/04/2021, passed under section 143(3) r/w section 144C(13) r/w section 144B of the Income ... evidence test vis–a–vis the reimbursement of expenses. In conformity with the directions issued by the learned DRP, the A.O. passed impugned final assessment order dated 27/04/2021. Being aggrieved, the assessee is in appeal before us. 7. During the course of hearing, the learned Authorised Representative (“learned A.R.”) submitted