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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

The Bank of Tokyo Mitsubishi Ufj, New Delhi vs. DCIT, Circle- 3(1)(1), International Taxation, New Delhi

ITA 7212/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 144Section 144C(5)Section 44C

Hearing 16.12.2025 Date of Pronouncement 13.03.2026 ORDER PER BRAJESH KUMAR SINGH, AM, This appeal filed by the assessee is directed against the Final Assessment Order (FAO) passed u/s 143(3) r.w.s.144C(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act') dated 31-10-2017 pursuant ... said income Rs, 668,07,07,663/- was denied by the Assessing Officer. The calculation of the taxable income in the final assessment order by the AO is reproduced as under. (Amount in INR) 1. Income as declared in ITR before deduction u/s 44C 5,25,56,05,326 Income

Merit Data and Technology Private Limited, Chennai vs. The Income Tax Officer, Corporate Ward 4(1) Chennai, Chennai

In the result, the appeal of the assessee is partly allowed and the stay application of the assessee is dismissed as infructuous

ITA 958/CHNY/2026[2022-23]Status: DisposedITAT Chennai12 Mar 2026AY 2022-23

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.958/Chny/2026 & Sa No.74/Chny/2026 (Arises In Ita No.958/Chny/2026) िनधा%रण वष% /Assessment Year: 2022-23 M/S. Merit Data & Technology Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward-4(1), Sp 52, 3Rd Street, Ambattur Industrial Chennai. Estate S.O., Ambattur, Tiruvallur – 600 058. Pan: Aadcl 8191M

For Appellant: Mr. K. Prasanna, C.A )*For Respondent: Mr. ARV Sreenivasan, CIT
Section 143(3)

giving effect whereby the TP adjustment was increased to Rs.8,60,29,525/-. The assessee is in appeal before the Tribunal against the final assessment order passed by the A.O pursuant to the directions of the DRP. 3. The facts pertaining to the impugned TP adjustment is that

Nisha Dudheria, Bangalore vs. Income Tax Officer, Ward-5(2)(3), Bengaluru

In the result the ground No

ITA 316/BANG/2025[2015-16]Status: DisposedITAT Bangalore12 Mar 2026AY 2015-16

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2015-16 Ms. Nisha Dudheria, 66, Navniketan, The Income Tax Officer, Kr Road, Basavanagudi, Ward-5(2)(3), Vs. Bangalore – 560 004. Bangalore. Pan: Bkrpd5938G Appellant Respondent Shri K.R. Pradeep, Advocate & Assessee By : Ms. Girija G.P., Advocate : Shri Subramanian – Jcit Dr Revenue By Date Of Hearing : 09-02-2026 Date Of Pronouncement : 12-03-2026

For Appellant: Ms. Girija G.P., Advocate
Section 142Section 143Section 148Section 68

prior to passing of the Reassessment Order. Page 5 of 8 Even otherwise the Assessing Officer was having the time for passing the final assessment order up to 31.03.2019. 8. The Hon’ble Supreme court in Deputy Commissioner of Income-tax vs. Hewlett Packard Financial Services (India

M/S. Hl Mando Anand India Pvt. Ltd., Kancheepuram vs. DCIT, Corp. Circle-1(4), Chennai

The appeal of the assessee is allowed for statistical purposes

ITA 2088/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Mar 2026AY 2017-18

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.2088/Chny/2025 िनधा#रण वष# /Assessment Year: 2017-18

For Appellant: Mr. Vikram Vijayaraghavan, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT
Section 115JSection 142(1)Section 143(3)Section 144Section 144BSection 144B(1)(xi)Section 144B(1)(xix)Section 144B(1)(xvi)Section 250Section 35

Before the CIT(A), the assessee raised a legal contention that NeAC did not file a draft assessment order prior to passing the final assessment order u/s. 143(3) of the Act. The assessee also raised grounds on merits with regard to disallowance of deduction claimed ... order, show cause M/s. HL Mando Anand India Pvt. Ltd. :- 3 -: notice after review by the Review Unit and subsequent passing of the final assessment order.” 3. The CIT(A) also dismissed the contentions of the assessee on merits. The assessee is in appeal before the Tribunal against the order

Jubilant Ingrevia Limited, Bhartiagram vs. Assistant Commissioner of Income Tax, Moradabad

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

ITA 5851/DEL/2024[2021-22]Status: DisposedITAT Delhi11 Mar 2026AY 2021-22

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanjubilant Ingrevia Ltd, Vs. Acit-1, Bhartiagram Bhartia Gram, So Moradabad, Up Dhanaura, Jyotiba Phule Nagar, Uttar Pradesh (Appellant) (Respondent) Pan: Aaecj6722D

For Appellant: Shri K. M. Gupta, AdvFor Respondent: Shri Jitendra Singh, CIT DR
Section 115Section 143(1)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 154Section 234ASection 234CSection 270A

basing adjustment of Rs. 14,60,01,550 which stood deleted by the Learned DRP vide its directions dated 30-9-2024. The final assessment order stood framed under section 143(3) read with section 144C(13) of the Act on 29-10-2024 determining the total income ... return of income of the assessee. As stated earlier, the Learned AO, both in the draft assessment order as well as in the final assessment order, started his computation of income from the income determined by the Learned CPC under Section 143(1) of the Act. By this process

Ge Engine Services Llc, United States of America vs. Assistant Commissioner of Income Tax, New Delhi

ITA 3700/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi11 Mar 2026

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 9(1)

Hearing | 12.12.2025 | Date of Pronouncement | 11.03.2026 ORDER PER BRAJESH KUMAR SINGH, AM, This appeal filed by the assessee is directed against the Final Assessment Order (FAO) passed u/s 143(3) r.w.s.144C(13) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') dated 20.10.2023 pursuant to the directions ... case B. Assessee's submission The above ground is a general ground. It is submitted that the Ld. AO has passed the final assessment order in complete disregard to facts and submission made by Appellant during the course of the assessment proceedings. 3.1 The above ground is general in nature

Chennai Metro Rail Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

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

ITA 3738/CHNY/2025[2017-18]Status: DisposedITAT Chennai10 Mar 2026AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3738/Chny/2025 "नधा"रण वष"/Assessment Year: 2018-19 Chennai Metro Rail Limited, V. Dcit, Metros Anna Salai, Corporate Circle -1(1), Nandanam, Chennai. Chennai – 600 035. [Pan:Aadcc 2233 K] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr. S. Sridhar, Advocate ""थ" की ओर से /Respondent By : Mr. Shiva Srinivas, C.I.T. सुनवाईक"तार"ख/Date Of Hearing : 10.03.2026 घोषणाक"तार"ख /Date Of Pronouncement : 10.03.2026

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. Shiva Srinivas, C.I.T
Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 2(45)Section 244ASection 40A(7)Section 43B

submit the response within the stipulated time. In the absence of a response, the AO added the differential amount to income in the final assessment order. The Assessee filed an appeal against the assessment order dated 26.04.2021, passed u/s. 143(3) read with Section 144B of the Income

Mitesh Suresh Shah, Mumbai vs. ITO International Taxation Ward 4(2)(1), Mumbai

In the result, the appeal filed by the assessee stands partly allowed with no order as to cost

ITA 5593/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Mar 2026AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarmitesh Suresh Shah Vs. Ito-International Tax 401, 4Th Floor, Blue Heaven, Ward-4(2)(1), Mumbai Nehru Road, Vakola, Kautilya Bhavan, Pipeline, Santacruz (East), Bandra Kurla Complex, Mumbai-400055 Bandra (East), Mumbai- 400051 Pan/Gir No. Auxps9395K (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya, Adv. Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 11.02.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 29.03.2022 Passed U/S 144C Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Income Tax Officer Ward 4(2)(1), Mumbai For The Assessment Year 2016-17. The Following Grounds Are Reproduced Below: “1. The Order Is Bad In Law, Illegal & Without Jurisdiction

Section 144CSection 147Section 68

scheme and as otherwise also is not in accordance with the law. 1.2 Without prejudice to the generality of the above, the final assessment order so passed is bad in law, illegal and void as the same is arbitrary and perverse. 2. DIRECTIONS ... facts and the circumstances of the case, and in law, the directions issued by the Ld. DRP as well as the final assessment order so framed, pursuant to the directions of DRP, is bad and illegal, as the same were framed in gross and flagrant breach of the principles

Zarah Rafique Malik, Mumbai vs. ITO (Int Tax) Ward-3(2)(1), Mumbai

ITA 5159/MUM/2025[2022-23]Status: DisposedITAT Mumbai10 Mar 2026AY 2022-23

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri Vikram Singh Yadav, Hon’Blezarah Rafique Malik Income Tax Officer, (Int.Tax) B/1703, Vivarea Condominium, Ward- 3(2)(1), Mumbai Vs. Sane Guruji Marg, Jacob Circle, Mahalaxmi East Mumbai – 400 011 Pan : Adcpm8960G (Appellant) (Respondent)

For Appellant: Shri K Gopal, Adv. & Shri Oom KandalkarFor Respondent: Shri Krishna Kumar, Sr. DR
Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 144BSection 153(1)

which mandates that assessments be conducted in a faceless manner, the said assessment proceedings are unlawful and void ab initio. C. The final assessment order dated 15.07.2025 passed u/s 143(3) r.w.s. 144C(13) of the Act is time barred: 3. The Ld. A.O. has passed the final assessment order ... specified under section 153(1) of the Act. Hence, the said assessment order is time barred and therefore, bad in law. 4. The final assessment order dated 15.07.2025 passed under section 143(3) r.w.s. 144C(13) of the Act is unlawful and without jurisdiction as the same is in contravention

Dy.Commissioner of Income Tax, Mumbai vs. Bp India Pvt Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 4907/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Mar 2026AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Deputy Commissioner Of Bp India Pvt. Ltd. Income Tax , Circle-1(2)(1), P B No 19411, Mumbai Vs. Technopolis Knowledge Park, Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) C.O. No. 276/Mum/2025 Assessment Year: 2011-12 Bp India Pvt. Ltd. Deputy Commissioner Of Income P B No 19411, Tax , Circle-1(2)(1), Technopolis Knowledge Park, Vs. Mumbai Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) Present For: Assessee : Ms. Chandni Shah, Mr. Amol Mahajan & Ms. Nidhi Agarwal, Cas Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue & Cross Objection Filed By The Assessee Against The Order Of Cit (A) 55, Mumbai, Vide Order No. Itba/Apl/S/250/2025-26/1076574916(1), Dated 30/05/2025, Passed Against The Assessment Order By Acit - 9(2)(1), Mumbai, U/S. 143(3) R.W.S 144(C)(3)(B) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 13.04.2015, For Assessment Year 2011-12. 2

For Appellant: Ms. Chandni Shah, Mr. Amol Mahajan and Ms. Nidhi Agarwal, CAsFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 143(3)

service rendered to the AEs other than BPXA. 3. On the facts and in the circumstances of the case and in law, the final assessment order, dated 13 April 2015, having been passed beyond limitation period provided in terms of section 153 of the Act, is invalid

Firstrand Bank Limited - India Branch, Mumbai vs. Assistant Commissioner, Mumbai

In the result, appeal of the assessee is allowed

ITA 4580/MUM/2024[2020-21]Status: DisposedITAT Mumbai10 Mar 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 133(6)Section 144C(5)Section 92C

Date of Pronouncement : 10.03.2026 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the final assessment order passed pursuant to the directions of the Dispute Resolution Panel-1, Mumbai, (DRP) vide order No. ITBA/DRP/F/144C(5)/2024- 25/1065484084(1) dated ... guarantee commission and directed to compute the ALP for the same by applying a rate of 1.80%. Pursuant to the said directions, final assessment order was passed, determining the total income at nil but with the balance losses at a reduced amount, for carry forward at Rs.190

Gemological Institute of America, Inc., United States of America vs. The Assistant Commissioner of Income-Tax (International Taxation), Range 2(3)(2) - Mumbai, Mumbai

Accordingly this ground raised by the assessee stands allowed in terms of above directions

ITA 8248/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankargemological Institute Of Vs. Acit (International America Taxation), Range - 5345, The Robert Mouawad 2(3)(2) Mumbai Campus, Armada Drive, Room No. 610, 6Th Carlsbad, Floor, Kautilya Bhavan, California - 092008 Bandra Kurla Complex, Bandra (East) Mumbai – 400051 Pan/Gir No. Aadcg7962K (Applicant) (Respondent) Assessee By Shri J.D. Mistry-Sr. Adv./Gunjan Kakkad Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 03.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 03.09.2025 Passed U/S 143(3) R.W.S. 254 Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Assistant Commissioner Of Income Tax, Circle 2(3)(2), Mumbai, For The Assessment Year 2020-21. The Following Grounds Are Reproduced Below:

Section 143(3)Section 144C(5)Section 244ASection 92C

accordingly. 1:4 The Appellant requests that the Assessing Officer be directed to expunge his remark on page No. 07 of the impugned Final Assessment Order dated 03 September 2025 wherein it has been mentioned that "Royalty income attributable to PE as discussed in the original assessment order dt. 12/01/2023

Amith Vishnav Gudimella, Hyderabad vs. ITO, Ward-12(1), Hyderabad

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

ITA 1705/HYD/2025[2020-21]Status: HeardITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: MS Reema Yadav, Sr. AR
Section 143(1)Section 154Section 90Section 91

present case. In the present case, the returns were filed without FTC, however the same was filed before passing of the final assessment order. The filing of FTC in terms of the Rule 128 is only directory in nature. The rule is only for the implementation of the provisions ... petitioner on 02.02.2021. 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 FTC claim made by the petitioner

Income Tax Officer, Ward-9(1), Kolkata vs. Littlestar Securities Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 694/KOL/2025[2012-13]Status: DisposedITAT Kolkata06 Mar 2026AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Manjeet Singh, DR
Section 143(3)Section 144BSection 254Section 68

scrutiny assessment was completed on 27.09.2021. After a gap of 13/14 years, after actual transactions had taken place and final assessment orders had been passed, proceedings was initiated. Thus, the predicament faced by the assessee was taken note by the learned Tribunal and it had observed that it is practically

Dy Commissioner of Income Tax (Int Tax)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

Appeal are dismissed

ITA 34/MUM/2026[2010-11]Status: DisposedITAT Mumbai06 Mar 2026AY 2010-11

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

For Appellant: Shri Krishna KumarFor Respondent: Shri Pratik Poddar, Shri Karan Jain
Section 144CSection 271(1)(c)

additional ground of appeal. From the submissions made by rival sides the fact emerges that in the second round, the AO passed final assessment order dated 29/12/2016 without passing the draft assessment order. 10. Provisions of section 144C of the Act lays down the procedure to be followed under special ... file objections, against such variations before the DRP. If no objections are filed against the draft assessment order, the AO shall pass the final assessment order. In case the objections are filed before the DRP, the DRP shall issue the directions and it is only after the directions

Ca (India) Technologies P.Ltd, Mumbai vs. ITO RG 14(1)(4), Mumbai

In the result, the appeal is dismissed

ITA 7381/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey, Vp & Shri Makarand Vasant Mahadeokar, Am Ca (India) Technologies Private The Income Tax Officer-14(1)(4) Limited Room No. 458, Aayakar Bhavan, Ground Floor, Vibgyor Tower, Mumbai-400 020 Plot C-62, G-Block, Vs. Bandra Kurla Complex, Bandra (E), Mumbai-400 051 Pan/Gir No. Aaacc 4971 D (Appellant) : (Respondent) Appellant By : None Respondent By : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 06.03.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Makarand V. Mahadeokar, Am: This Is An Appeal By The Assessee Against Order Dated 18.09.2018 Of First Appellate Authority, Pertaining To Assessment Year (A.Y.) 2014-15. 2. The Assessee Vide Letter Dated 26.02.2026 Has Submitted That The Dispute Has Been Resolved Through Mutual Agreement Procedure (“Map”) & The Assessee Has Accepted The Map Resolution, Hence, Request Has Been Made For Withdrawal Of The Appeal. The Contents Of The Said Letter Are As Under: Dear Sir, Re: Ca (India) Technologies Private Limited ('Ca India' Or 'Appellant') Permanent Account Number ('Pan'): Aaacc4971D Assessment Year ('Ay'): 2014-15 Appeal No. Ita 7381/Mum/2018

For Appellant: NoneFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 144C

adjustment to Royalty payments (Royalty') of INR 98,463 297. In this regard, the Appellant filed an appeal before your Honours against the final assessment order passed by the Ld. AO 2. During the pendency of above appeal proceedings, the Associated Enterprise (AE') of the Appellant lie. filed

Cisco Commerce India Private Limited, Bangalore vs. Principal Commissioner of Income Tax, PCIT, Bengaluru-2, Bangalore

In the result, the appeal by the assessee is dismissed

ITA 1235/BANG/2025[2021-22]Status: DisposedITAT Bangalore05 Mar 2026AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2021-22

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Smt. N. Hemalatha, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 154Section 194JSection 263Section 40

Assessee has raised following grounds of appeal: “1. Ld. PCIT has erred in assuming jurisdiction under section 263 of the Act to revise final assessment order dated December 26, 2022 without jurisdictional preconditions being satisfied. 2. Impugned order failed to appreciate that deductibility of rebates, discount, refund liabilities and incentive ... subject matter of appeal before CIT(A) as Ld. AO made disallowance of INR 83.64 Crores in final assessment order. 3. Ld. PCIT's suspicion of final order being 'erroneous' arises from baseless assumption of failure of AO to enquiry and is dehors and directly contrary to material on assessment

ACIT, Circle-3, Gurugram, Gurgaron vs. Perfetti Van Melle Inida Private Limited, Gurgaon

In the result the appeal of the revenue stands dismissed

ITA 623/DEL/2025[2010]Status: DisposedITAT Delhi05 Mar 2026

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Circle-3 Vs. Perfetti Van Melle India 2Nd Floor, Hshdc Pvt. Limited, Building, Shankar Chowk, 47, Milestone Delhi Jaipur Gurugram, Highway Manesar Haryana – 122001 Haryana - 122051 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacp2626A Appellant .. Respondent

For Appellant: Sh. Anmol Anand, AdvFor Respondent: Ms. Pooja Swaroop, CIT (DR)
Section 143(3)Section 144C(13)Section 263Section 80

case of the Assessee for AY 2010-11 was picked up for scrutiny, and a final assessment order dated 05.01.2015 was passed by the AO under section 144C(13) read with section 143(3) of the Act. In the said order, the AO accepted the eligibility of the Assessee

Amit Shantaram Bagade Mited, Mumbai vs. Income Tax Officer Int Taxation Ward 1(2), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 832/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Mar 2026AY 2019-20

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

VIKRAM SINGH YADAV, A.M : These are two appeals filed by the assessee against the respective final assessment orders dated 12-12-2024 & 20-08-2025 passed u/s. 147 r.w.s. 144C(13) of the Income Tax Act, 1961 („the Act‟), pursuant to the directions issued by the Learned

Amit Shantaram Bagade, Thane vs. ITO (Int Tax) Ward-1(2)(1), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 6286/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Mar 2026AY 2020-21

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

VIKRAM SINGH YADAV, A.M : These are two appeals filed by the assessee against the respective final assessment orders dated 12-12-2024 & 20-08-2025 passed u/s. 147 r.w.s. 144C(13) of the Income Tax Act, 1961 („the Act‟), pursuant to the directions issued by the Learned