“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

Multi Commodity Exchange of India Ltd., Mumbai vs. Pr CIT (Central)-4, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 953/MUM/2021[2014-15]Status: DisposedITAT Mumbai27 Apr 2022AY 2014-15

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Blemulti Commodity Exchange Of V. Pr.Cit –(Central)-4 India Limited 6Th Floor, Room No. 663 Cts 255, Exchange Square Suren Road Aayakar Bhavan, M.K. Road Chakala Andheri (E) Mumbai - 400020 Mumbai – 400093 Pan: Aadcm8239K (Appellant) (Respondent) Assessee By : Shri P.J. Pardiwala & Shri Tanzil Padvekar Department By : Shri Sanjeev Kashyap

For Appellant: Shri P.J. Pardiwala &For Respondent: Shri Sanjeev Kashyap

Section 143(2)Section 143(3)Section 263Section 92C

taken cognizance of the findings of the PWC Special Audit report while making the adjustment and to the extent, the final assessment order dated 21.01.2019 passed u/s 143(3) r.w.s 144C(3) of the Act is erroneous in so far as it is prejudicial to the interests of the revenue

M/S. Steer Engineering Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income-Tax, Circle-6(1)(2), Bengaluru

In the result, appeal of the Assessee is partly allowed

ITA 2071/BANG/2018[2012-13]Status: DisposedITAT Bangalore27 Apr 2022AY 2012-13

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathyassessment Year : 2012-13 M/S. Steer Engineering Private Limited, Vs. Dcit, No.290, 4Th Main, 4Th Phase, Circle – 6(1)(2), Peenya Industrial Area, Nagawara, Bengaluru. Bengaluru – 560 058. Pan : Aabcs 8840 E Appellant Respondent Assessee By : Shri. Narendra Jain, Advocate Revenue By : Mrs. Susan D. George, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 18.04.2022 Date Of Pronouncement : 27.04.2022

For Appellant: Shri. Narendra Jain, AdvocateFor Respondent: Mrs. Susan D. George, CIT(DR)(ITAT), Bengaluru

Section 144CSection 92(1)Section 92ASection 92A(1)Section 92CSection 92C(2)Section 92F

guidance of the AO to enable him to complete the assessment after considering report of TPO. The AO passes a final assessment order on the basis of directions of the DRP. In case the Assessee chooses not to filed objections before the DRP to the draft assessment order within ... time required u/s.144C of the Page 4 of 33 Act, the AO passes a final assessment order. The Assessee has a right of appeal against the said order to the CIT(A), which course the Assessee has adopted in the present case. 5. During the previous year, the Assessee entered

M/S Belgacom International Carrier Services Sa, Bangalore vs. Deputy Commissioner of Income Tax Circle-1(1) International Taxation, Bangalore

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

ITA 2884/BANG/2017[2008-09]Status: DisposedITAT Bangalore26 Apr 2022AY 2008-09

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(It)A No. 2884/Bang/2017 Assessment Year : 2008-09 M/S. Belgacom The Deputy International Carrier Commissioner Of Services Sa, Income Tax, Rue Lebeau 4, Circle -1(1), 1000 Brussels, International Taxation, Vs. Belgium. Bangalore. Appellant Respondent : Shri V. Sridharan, Senior Assessee By Advocate : Shri Pradeep Kumar, Cit-Dr & Revenue By Smt. Vandana Sagar, Cit-Dr Date Of Hearing : 16-03-2022 Date Of Pronouncement : 26-04-2022 Order Per Beena Pillaipresent Appeal Is Filed By Non Resident Assessee Against Order Dated 30.10.2017 Passed By Dcit (It), Circle -1(1), Bangalore On Following Grounds Of Appeal: “Being Aggrieved By The Order Of The Learned Dcit, Circle - 1(1), International Taxation, Bengaluru ('A0'), Read With The Order Of The Learned Dispute Resolution Panel ('Drp*), Bengaluru, The Assessee Begs To Prefer The Present Appeal On The Following Grounds: 1. The Learned Ao Erred In Exercising, Jurisdiction U/S 147 Of The Act In The Case Of The Appellant. 2. The Lower Authorities Erred In Holding That A Sum Of Rs. 6,87,13,119/- Received By The Appellant From Its Customer In India Is In The Nature Of 'Royalty' Within The Meaning Of Section 9(1)(Vi) Of The It Act & Accordingly Taxable In India Under The It Act.

For Respondent: Shri V. Sridharan, Senior

Section 143(3)Section 147Section 148Section 234ASection 234BSection 234CSection 9(1)(v)Section 9(1)(vi)Section 9(1)(vii)

academic in nature. Page 4 IT(IT)A No. 2884/Bang/2017 4. On receipt of the DRP directions, the Ld.AO passed the final assessment order dated 30.10.2017 and held the assessee to be taxable in India. Aggrieved by the final assessment order passed by the Ld.AO, the assessee is in appeal

Verifone India Technology Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-7(1)(2), Bangalore

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

ITA 290/BANG/2021[2016-17]Status: DisposedITAT Bangalore25 Apr 2022AY 2016-17

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 143(3)

direction of Ld. DRP, interest on delayed receivables worked out to Rs.1,91,11,071/-, which was added by the A.O. in the final assessment order. Aggrieved, the assessee has filed this appeal before us. 3. The Ld A.R submitted that the assessee is not disputing the view taken

Dy CIT (It)-3(3)(2), Mumbai vs. M/S Pramerica Aspf II Cyprus, Haryana

In the result, the appeal is dismissed

ITA 6751/MUM/2019[2014-15]Status: DisposedITAT Mumbai21 Apr 2022AY 2014-15

Section 143Section 143(3)Section 144CSection 292B

variation has been proposed therein to the income or loss returned by the appellant. The learned AO has erred in passing the final assessment order under section 143(3) of the Act, after the due date provided under section 153 of the Act, thus making the final assessment order illegal

B. Barun Medical (India) Private Limited, Mumbai vs. DCIT-9(2)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 7417/MUM/2018[2014-15]Status: DisposedITAT Mumbai20 Apr 2022AY 2014-15

Bench: Us.

Section 143(3)Section 144C(5)

आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.7417/Mum/2018 for A.Y.2014-15 preferred by the order against the final assessment order passed by the Assessing Officer dated 30/12/2018 u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant

Epson India Private Limited, Ulsoor vs. Deputy Commissioner of Income Tax, International Taxation, Circle-1(2), Bangalore

In the result, the appeal of the assessee is allowed

ITA 205/BANG/2021[2015-16]Status: DisposedITAT Bangalore18 Apr 2022AY 2015-16

Bench: Shri N V Vasudevan & Ms. Padmavathy S

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Dr. Manjunath Karkihalli, CIT DR

Section 143Section 147Section 148Section 92Section 92(1)Section 92B(1)

wide direction dated 15.02.2021 upheld the action of the TPO. Pursuant to the directions of the DRP the AO passed final assessment order. Aggrieved by the final assessment order the assessee filed the appeal before the Tribunal. 4. The assessee has raised grounds with respect to legal issues and grounds

Royal Home Collections Private Limited, Mumbai vs. ACIT-4(2)(1), Mumbai

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

ITA 910/MUM/2019[2014-15]Status: DisposedITAT Mumbai13 Apr 2022AY 2014-15

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm आयकरअपीलसं./ I.T.A. No. 910/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Acit-4(2)(1), Royal Home Collections R. No. 642, 6Th Floor, Pvt. Ltd. Aayakar Bhavan, बिधम/ Plot No. 33, Abcd Govt. Mumbai-400 020 Industrial Estate, Charkop, Vs. Kandivali, Mumbai-400 067 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaccm4922G (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant None : By प्रत्यथीकीओरसे/Respondent : Shri T. Shankar, Ld. Dr By सुनवाईकीतारीख/ : 09.03.2022 Date Of Hearing घोषणाकीतारीख / : 13.04.2022 Date Of Pronouncement आदेश / O R D E R Per Kavitha Rajagopal: The Present Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A)-9, Mumbai Dated 30.01.2019 Pertains To Ay 2014-15. The Solitary Ground Of Appeal Is Whether The Ld. Cit(A) Has Erred In Upholding The Penalty Of Rs. 10,000/- Levied U/S 271(1)(B) Of The I.T. Act.

For Respondent: Shri T. Shankar, Ld. DR by

Section 142(1)Section 143(2)Section 143(3)Section 144Section 271(1)(b)

hence the assessee company is in appeal before us. 4. The Ld. AR contended that the assessee company was assessed and the final assessment order was passed u/s 143(3) of the Act and not u/s 144 which is best judgment assessment. The Ld. AR further contended that the subsequent ... compliance of the assessee company in furnishing the required details during the course of assessment proceedings. It is also evident that the final assessment order was passed u/s 143(3) of the Act not u/s 144 of the Act. Though there was non compliance on the part of the assessee

Australia and New Zealand Banking Group Ltd, Mumbai vs. DCIT 1(1)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1106/MUM/2017[2012-13]Status: DisposedITAT Mumbai13 Apr 2022AY 2012-13

Section 143(3)Section 144C(5)

आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.1106/Mum/2017 for A.Y.2012-13 preferred by the order against the final assessment order passed by the Assessing Officer dated 14/12/2016 u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant ... Australia and New Zealand Banking Group Ltd., 3.4. The very same TP adjustment was incorporated in the final assessment order passed by the ld. AO u/s.143(3) r.w.s. 144(C) (13) of the Act dated 14/12/2016 pursuant to the directions of the ld. DRP. 3.5. At the outset, we find

Netapp India Marketing and Services Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-5(1)(1), Bangalore

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

ITA 181/BANG/2021[2016-17]Status: DisposedITAT Bangalore13 Apr 2022AY 2016-17

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Sri G.C. Srivastava, A.RFor Respondent: Sri Manjunath Karkihalli, D.R

Section 143(3)

Bangalore Page 3 of 6 4.4985%. The Ld. DRP confirmed the adjustment made by the TPO. The A.O. accordingly passed the final assessment order by making addition of transfer pricing adjustment referred above. Aggrieved, the assessee has filed this appeal before us. 4. With regard to transfer pricing adjustment

Lokesh Talanki, Bangalore vs. The Assistant Commissioner of Income Tax Circle-2(3)(1), Bangalore

In the result, appeals of the assessee are allowed

ITA 261/BANG/2019[2013-14]Status: DisposedITAT Bangalore13 Apr 2022AY 2013-14

Bench: Shri Beena Pillai & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri Deepesh Waghale CAFor Respondent: Shri Shehnawaz Ul Rahaman Addln CIT

Section 142(1)Section 143(2)Section 143(3)Section 148Section 234BSection 54F

subjected to assessment and was left out while working out the taxable income and the tax payable thereon, i.e., while making the final assessment order, that would enable him to initiate the proceedings irrespective of the question of non- disclosure of material facts by the assessed." 28. We are, with

The Indian Hotels Co. Ltd., Mumbai vs. Pr. CIT-1, Mumbai

In the result, the appeal of the assessee is hereby allowed

ITA 950/MUM/2021[2014-15]Status: DisposedITAT Mumbai12 Apr 2022AY 2014-15

Bench: Shri Amarjit Singh, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.950/Mum/2021 (ननधधारण वर्ा / Assessment Years: 2014-15) बनधम/ The Indian Hotels Company Pcit-1 Room No.330, 3Rd Floor, Ltd. Vs. 9Th Floor, Express Towers, Aayakar Bhavan, Barrister Rajini Patel Marg, Maharishi Karve Road, Nariman Point, Mumbai- Mumbai-400020. 400021. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaact3957G (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri K. K. Ved Revenue By: Shri Surendra Kumar (Dr) सुनवाई की तारीख / Date Of Hearing: 17/03/2022 घोषणा की तारीख /Date Of Pronouncement: 12/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 31.03.2021 Passed By The Principal Commissioner Of Income Tax-01, Mumbai [Hereinafter Referred To As The “Pcit”] Relevant To The A.Y.2014-15 In Which The Principal Commissioner Of Income Tax-01 Has Invoked The Revisional Power U/S 263 Of The I.T. Act, 1961. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “Re.: Validity Of Order U/S, 263; On The Facts & In The Circumstances Of The Case & In Law, The Impugned Order Dated 31 March 2021 Passed Under Section 263 Of The Act Is Without Jurisdiction & Bad In Law. Without Prejudice To The Above, On The Facts & Circumstances Of The Case & In Law, The Principal Commissioner Of Income Tax (“Pcit”) Has Erred In Passing The Order Dated 31 March 2021 U/S. 263 Of The Act.

For Appellant: Shri K. K. VedFor Respondent: Shri Surendra Kumar (DR)

Section 143(3)Section 144CSection 263Section 36

issues, that AO has not properly followed the direction u/s. 144A. But, he is quiet silent and has nowhere mentioned that the final assessment order is passed after the direction of DRP. Admittedly, this is not a case, where draft assessment order is being revised. This is a case where ... final assessment order passed pursuant to the direction of DRP u/s. 144(3) is being revised by Ld.CIT. Ld. Counsel of the assessee in this regard submits that from the Finance Act, 2009, memorandum explaining the rationale behind the insertion of section 144C of the Act by the Finance Bill

M/S. Biocon Research Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle- 1(1)(2), Bangalore

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

ITA 2612/BANG/2019[2015-16]Status: DisposedITAT Bangalore11 Apr 2022AY 2015-16

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Padamchand Khincha, A.RFor Respondent: Sri Manjunath Karkihalli, DR

Section 10ASection 143(3)

Date of Pronouncement : 11.04.2022 O R D E R PER B.R. BASKARAN, ACCOUNTANT MEMBER: The assessee has filed this appeal challenging the final assessment order dated 30-10-2019 passed by the assessing officer for assessment year 2015-16 u/s 143(3) r.w.s 144C(13) of the Income

M/S. Nsl Sugars Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-5(1)(1), Bangalore

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

ITA 262/BANG/2021[2016-17]Status: DisposedITAT Bangalore08 Apr 2022AY 2016-17

Bench: Shri N.V.Vasudevan, Vp & Ms.Padmavathy S, Am It(Tp)A No.262/Bang/2021 : Asst.Year 2016-2017 M/S.Nsl Sugars Limited The Assistant Commissioner Of 60/1, 2Nd Cross V. Income-Tax, Circle 5(1)(1) Residency Road Bangalore. Bangalore – 560 025. Pan : Aagcs0938Q. (Appellant) (Respondent) Appellant By : Sri.T.Gandhi, Advocate Respondent By : Dr.Manjunatha Karkihalli, Cit-Dr Date Of Date Of Hearing : 05.04.2022 Pronouncement : 08.04.2022 O R D E R Per Padmavathy S, Am : This Appeal Is Against The Order Of The Dcit Passed U/S 143(3) R.W.S. 144C Of The I.T.Act, 1961 (“The Act”) Dated 30.04.2021 For The Assessment Year 2016-2017. Brief Facts Of The Case 2. The Assessee Is A Company Engaged In The Business Of Manufacture Of Sugar & Molasses Etc. It Filed The Return Of Income For The Assessment Year 2016-2017 On 30.11.2016 With Returned Loss Of Rs.78,24,50,827. The Case Was Selected For Scrutiny & Notice U/S 143(2) Of The Act Was Issued. Reference Was Made To The Transfer Pricing Officer (Tpo) For Determination Of Arm’S Length Price (Alp) Of The Specified Domestic Transactions Entered Into By The Assessee. The Tpo Passed An Order U/S 92Ca On 30.10.2019 Proposing The Adjustment Of Rs.96,57,60,845. The Assessing Officer (Ao) Passed A Draft Assessment Order On 23.12.2019 Incorporating The Tp Adjustment Proposed By The Tpo. In Addition, The Ao

For Appellant: Sri.T.Gandhi, AdvocateFor Respondent: Dr.Manjunatha Karkihalli, CIT-DR

Section 143(2)Section 143(3)Section 14ASection 43BSection 92C

pricing adjustment made by the TPO and sustained the additions made by the AO on the corporate tax issue. The AO passed the final assessment order giving effect to the directions of the DRP. 3. Aggrieved by the order of the AO, the assessee is in appeal before the Tribunal

Xerox Business Services India Private Limited, Bangalore vs. Asst.C.I.T., Bangalore

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

ITA 361/BANG/2016[2011-12]Status: DisposedITAT Bangalore08 Apr 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT-DR

Section 143(3)Section 144Section 144C(5)Section 144C(6)Section 92C

incorrectly following the directions of the Hon'b]e DRP and incorrectly computing an adjustment of INR 13,80,12,433 in the final assessment order. 6. The learned AO/DRP/TPO has erred, in law and on facts by not appreciating that the Appellant is a captive service provider, carrying

M/S.Tokai Rika Minda India Pvt. Ltd., Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

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

ITA 2327/BANG/2016[2012-13]Status: DisposedITAT Bangalore08 Apr 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2327/Bang/2016 : Asst.Year 2012-2013 M/S.Tokai Rika Minda India The Deputy Commissioner Of Private Limited Income-Tax, Circle 7(1)(1) V. Bangalore. Plot No.365, Sompura 1St Stage Kiadb Industrial Area Dobbaspet, Nelamangala Taluk Bangalore Rural Dist – 562 111. Pan : Aadct0271C. (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Pradeep Kumar, Cit-Dr Date Of Pronouncement : 08.04.2022 Date Of Hearing : 22.03.2022

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

Section 143(3)

Hearing : 22.03.2022 O R D E R Per George George K, JM : This appeal at the instance of the assessee is directed against final assessment order passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. 2. Though the assessee has raised multifarious grounds in its memorandum of appeal, during ... recompute the TP adjustment without giving the benefit of proportionate adjustment on account of local purchases. Pursuant to the DRP’s directions, the final assessment order was passed. 6. Aggrieved by the final assessment order, the assessee has filed this appeal before the Tribunal. The assessee has filed a paper

Asst.CIT, Bangalore vs. M/S Xerox Business Services of India Pvt. Ltd., Bangalore

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

ITA 202/BANG/2016[2011-12]Status: DisposedITAT Bangalore08 Apr 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT-DR

Section 143(3)Section 144Section 144C(5)Section 144C(6)Section 92C

Strides Pharma Science Ltd, Navi Mumbai vs. Dy CIT 15 (3)(2), Mumbai

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

ITA 7992/MUM/2019[2015-16]Status: DisposedITAT Mumbai06 Apr 2022AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit Gandhi a/w Ms. Akshita BhandariFor Respondent: Ms. Vatsalaa Jha (CIT)

Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 92C

Order – 06.04.2022 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 31.10.2019, passed by the Assessing Officer under section 143(3) r/w section 144C(13) of the Income ... brief facts of the case pertaining to this issue as emanating from the record are: The Assessing Officer vide final assessment order dated 31.10.2019, levied interest amounting to Rs. 10,03,50,402, under section 234C of the Act. 52. During the course of hearing, the learned A.R. submitted that

Tata Consultancy Services Ltd, Mumbai vs. Asst CIT Ltu-1, Mumbai

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

ITA 1650/MUM/2016[2011-12]Status: DisposedITAT Mumbai06 Apr 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Ms. Vatsalaa Jha, CIT–DR

Section 115JSection 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 2(43)Section 37Section 40Section 90Section 91

./2016 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present appeals have been filed by the assessee and Revenue challenging final assessment orders dated 25.10.2010 and 29.01.2016, passed by the Assessing Officer under section 143(3) r/w section 144C(13) Income ... case for the assessment year 2005–06. In conformity with the directions issued by the DRP, the A.O. has passed the impugned final assessment order. Being aggrieved, the assessee is in appeal before us. 7. During the course of hearing, Shri Porus Kaka, the learned Sr. Counsel appearing

Credit Suisse Consulting (India) P. Ltd, Mumbai vs. DCIT RG 3(1), Mumbai

619/Mum/2014

ITA 619/MUM/2014[2009-10]Status: DisposedITAT Mumbai05 Apr 2022AY 2009-10

Section 143(3)Section 144C(5)

Year:2010-11) These appeals in IT(TP)A Nos.619/Mum/2014 & 83/Mum/2015 for A.Yrs.2009-10 & 2010-11 preferred by the order against the final assessment order passed by the Assessing Officer dated 31/10/2014 & 27/11/2013 respectively u/s.143(3) r.w.s.144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant ... No.751/Mum/2016 (Assessment Year:2011- 12) These appeals in IT(TP)A Nos.745/Mum/2016 & 751/Mum/2016 for A.Yr.2011-12 preferred by the order against the final assessment order passed by the Assessing Officer dated 15/12/2015 u/s.143(3) r.w.s.144C(13) of the Income Tax Act, hereinafter referred to as Act, pursuant