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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

Marks and Spencer (India) Private Limited, Gurgaon vs. ACIT, Circle 1(1), Gurgaon

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

ITA 1937/DEL/2022[2018-19]Status: DisposedITAT Delhi05 Jan 2026AY 2018-19

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 92C

dated June 24, 2022 and referred pages 19 to 25 of Appeal set for the DRP directions. 12. Thereafter, the AO issued the final assessment order wherein adjustment of Rs.6,21,87,194 was made in the case of assessee and referred pages 7to 10 of the Appeal ... final assessment order. 13. With regard to final assessment order, ld. AR submitted before us that it is pertinent to mention that the Final Assessment Order was passed by the Jurisdictional Assessing Officer (‘JAO’) instead of National Faceless Assessment Centre (‘NFAC’). As per section 144Bof the Act, all assessment under

Ishares Core Msci Total International Stock Etf (As A Successor to Ishare Core Taotal International Stock Mauritius Company ), Mumbai vs. Dy CIT (Int. Tax)-2(2)(1), Mumbai

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

ITA 6774/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

Date of Order – 02/01/2026 O R D E R PER BENCH The present appeals have been filed by separate assessees against the separate final assessment orders passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued ... judicial finality on this issue. 11. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order under section 143(3) read with section 144C(13) of the Act computing the net short-term capital gains amounting

Ishares Core Msci Emerging Markets Etf (As A Successor to Ishares Core Emerging Markets Mauritius Company, Mumbai vs. DCIT (Tp) 2(2)(2), Mumbai

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

ITA 6051/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

Date of Order – 02/01/2026 O R D E R PER BENCH The present appeals have been filed by separate assessees against the separate final assessment orders passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued ... judicial finality on this issue. 11. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order under section 143(3) read with section 144C(13) of the Act computing the net short-term capital gains amounting

Ishares Msci All Country Asia Ex Japan Etf, Mumbai vs. DCIT (Int. Tax)-2(2)(2), Mumbai

ITA 6050/MUM/2025[2022-23]Status: DisposedITAT Mumbai02 Jan 2026AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

Date of Hearing – 10/12/2025 Date of Order – 02/01/2026 ORDER PER BENCH The present appeals have been filed by separate assessees against the separate final assessment orders passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the separate directions issued ... judicial finality on this issue. 11. In conformity with the directions issued by the learned DRP, the AO passed the impugned final assessment order under section 143(3) read with section 144C(13) of the Act computing the net short-term capital gains amounting

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 7294/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

Hearing – 09/12/2025 Date of Order - 02/01/2026 ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeals against the separate final assessment order passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 ("the Act") pursuant to the directions issued ... circumstances of the case and in law, the directions of the Hon'ble Dispute Resolution Panel- II (DRP') and the final assessment order passed by the learned Deputy Commissioner of Income-tax 15(3)(1), Mumbai (DCIT) are bad in law and merit to be set aside. - Ground 2 Depreciation

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

Hearing - 09/12/2025 Date of Order - 02/01/2026 ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeals against the separate final assessment order passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 ("the Act") pursuant to the directions issued ... circumstances of the case and in law, the directions of the Hon'ble Dispute Resolution Panel- II (DRP') and the final assessment order passed by the learned Deputy Commissioner of Income-tax - 15(3)(1), Mumbai (DCIT) are bad in law and merit to be set aside. Ground 2 - Depreciation

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

Hearing – 09/12/2025 Date of Order - 02/01/2026 ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeals against the separate final assessment order passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 ("the Act") pursuant to the directions issued ... circumstances of the case and in law, the directions of the Hon'ble Dispute Resolution Panel- II (DRP') and the final assessment order passed by the learned Deputy Commissioner of Income-tax 15(3)(1), Mumbai (DCIT) are bad in law and merit to be set aside. Ground 2 - Depreciation

Thermo Fisher Scienftific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

Hearing - 09/12/2025 Date of Order - 02/01/2026 ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeals against the separate final assessment order passed under section 143(3) read with section 144C(13) of the Income Tax Act, 1961 ("the Act") pursuant to the directions issued ... circumstances of the case and in law, the directions of the Hon'ble Dispute Resolution Panel- II (DRP') and the final assessment order passed by the learned Deputy Commissioner of Income-tax - 15(3)(1), Mumbai (DCIT) are bad in law and merit to be set aside. Ground 2 - Depreciation

Pallavi Kamal Shah, Mumbai vs. Income Tax Officer, Income Tax Department

In the result, appeal of the assessee is dismissed

ITA 6317/MUM/2024[2013-2014]Status: DisposedITAT Mumbai31 Dec 2025AY 2013-2014

Bench: Shri Pawan Singh& Smt. Renu Jauhri(Physical Hearing) Pallavi Kamal Shah Ito, Ward-30(1)(1), Mumbai A-601, Bhimsen Chs Ltd., Marve Vs Maharashtra-400051. Road, Malad West, Maharashtra - 400064. [Pan: Avops7447Q] Appellant / Assessee Respondent / Revenue

Section 124Section 142Section 143(2)Section 144Section 144BSection 144B(1)(xiv)Section 144B(1)(xvi)Section 147Section 148Section 254(1)

case and in law the NFAC erred in not adjudicating the ground raised before it that the JAO erred in passing the final assessment order dated 24th September 2021 under section 147 r.w.s. 144 of the Act without complying with the mandatory requirements of section 144B

Schineler India Pvt Ltd, Mumbai vs. Dcitrg 15(3) (2), Mumbai

In the result, ground no. 6 raised by the assessee is allowed

ITA 724/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Schindler India Pvt Ltd Dcit Schindler House, Main Street, Range 15(3) (2) Hiranandani Gardens, Powai, Vs. Mumbai Mumbai - 400076 (Pan: Aaecs1548J) (Appellant) (Respondent) Present For: Assessee : Ms. Chandani Shah, Ms. Niddhi Agarwal & Ms. Riddhi Maru, Cas Revenue : Shri Ajay Chandra, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By National Faceless Assessment Centre, Delhi (Nfac) Vide Order No. Itba/Ast/S/143(3)/2021-22/1040015716(1) Dated 22.02.2022 U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”) Pursuant To The Directions Of Ld. Dispute Resolution Panel-2, Mumbai, (Drp) Vide Order No. Itba/Drp/F/144C(5)/2021-22/1039079646(1), Dated 25.01.2022, Passed U/S. 144C(5), For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under: “Ground I. Legal Grounds

For Appellant: Ms. Chandani Shah, Ms. Niddhi Agarwal and Ms. Riddhi Maru, CAsFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144C(5)Section 92CSection 92C(3)

Date of Pronouncement : 31.12.2025 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the final assessment order passed by National Faceless Assessment Centre, Delhi (NFAC) vide order no. ITBA/AST/S/143(3)/2021-22/1040015716(1) dated 22.02.2022 u/s. 143(3) r.w.s. 144C ... observing that assessee had failed to prove that these expenses are incurred wholly and exclusively for the purpose of business. Final assessment order was passed whereby transfer pricing adjustment as proposed by the ld. TPO were included however, no such disallowance was made u/s. 37(1) while computing the total

DCIT, Bangalore vs. M/S Thomson Reuters India Services Pvt. Ltd., Bangalore

In the result, appeal filed by revenue in IT(TP)

ITA 843/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

Date of Pronouncement 31.12.2025 ORDER Per Smt. Beena Pillai, JM: Present appeals filed by assessee as well as revenue arises out of final assessment order dated 29/01/2025 passed u/s 143(3) 2 I.T.A. No. 234/Bang/2015 I.T.A. No. 843/Bang/2015 I.T.A. No. 542/Bang/2015 r.w.s. 144C(13) of the Act for assessment year

M/S Thomson Reuters International Services Private Limited, Mumbai vs. DCIT, Bangalore

ITA 542/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

Date of Pronouncement 31.12.2025 ORDER Per Smt. Beena Pillai, JM: Present appeals filed by assessee as well as revenue arises out of final assessment order dated 29/01/2025 passed u/s 143(3) 2 I.T.A. No. 234/Bang/2015 I.T.A. No. 843/Bang/2015 I.T.A. No. 542/Bang/2015 r.w.s.144C(13) of the Act for assessment year

DCIT, Bangalore vs. M/S Thomson Corporation (International) Pvt. Ltd., Bangalore

ITA 234/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)Section 7A

Date of Pronouncement 31.12.2025 ORDER Per Smt. Beena Pillai, JM: Present appeals filed by assessee as well as revenue arises out of final assessment order dated 29/01/2025 passed u/s 143(3) 2 I.T.A. No. 234/Bang/2015 I.T.A. No. 843/Bang/2015 I.T.A. No. 542/Bang/2015 r.w.s.144C(13) of the Act for assessment year

Bechtel Ltd, London vs. ACIT, Circle 1(1)(2), International Taxation, New Delhi

In the result, appeal of the assessee is allowed

ITA 756/DEL/2023[2020-21]Status: DisposedITAT Delhi31 Dec 2025AY 2020-21
Section 143(2)Section 143(3)Section 144C(13)Section 44DSection 9(1)(vii)

India, such receipts have to taxed as FTS u/s 44DA of the Act on “protective basis”. Thereafter, Assessing Officer passed the final assessment order dated 09.06.2022 wherein it had reproduced the entire draft assessment order and the order of Ld. DRP and computed the income of the assessee by taxing ... assessee has taken additional ground of appeal which reads as under: “ That on facts and circumstances of the present case, the Final Assessment Order dated 09.06.2022 passed by the AO, is void and illegal and therefore, the same deserves to be quashed, owing to non-adherence

Bechtel Limited, London vs. ACIT, Circle Int. Tax 1(1)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 1816/DEL/2022[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19
Section 143(2)Section 143(3)Section 144C(13)Section 44DSection 9(1)(vii)

India, such receipts have to taxed as FTS u/s 44DA of the Act on “protective basis”. Thereafter, Assessing Officer passed the final assessment order dated 09.06.2022 wherein it had reproduced the entire draft assessment order and the order of Ld. DRP and computed the income of the assessee by taxing ... assessee has taken additional ground of appeal which reads as under: “ That on facts and circumstances of the present case, the Final Assessment Order dated 09.06.2022 passed by the AO, is void and illegal and therefore, the same deserves to be quashed, owing to non-adherence

Luxottica India Eyewear Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

Appeal of the assessee is allowed for statistical purposes

ITA 1492/DEL/2015[2010-11]Status: DisposedITAT Delhi31 Dec 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Manish Agarwalluxottica India Eyewear Pvt. Ltd., Asst. Cit, 7Th Floor, Dlf Building No.9, Circle-15(2), Tower-B, Phase-Iii, Dlf Cyber Vs. New Delhi. City, Gurgaon-122002, Haryana. Pan-Aabcl3871C (Appellant) (Respondent) Assessee By Ms. Tanmayee Rajkumar, Adv., Ca Department By Shri Dheeraj Kumar Jaiswal, Sr. Dr Date Of Hearing 28.10.2025 Date Of Pronouncement 31.12.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 30.01.2015 Passed U/S 143(3) R.W.S.144C(1) Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’) In Compliance To The Direction Given By Ld. Dispute Resolution Panel (Drp) Vide Order Dated 15.12.2014 For Asst. Year 2010-11. 2. In The Present Appeal, The Co-Ordinate Bench Vide Order Dated 26.05.2017 In Ita No.1492/Del/2015 Has Remand The Issue Of Tp Adjustment Towards Alleged Amp Expenses To The File Of Tpo To Decide Afresh With Certain Directions, However, Luxottica India Eyewear Pvt. Ltd. Vs. Acit Ground In Respect Of Tp Adjustment Made Towards International Transactions Of Import Of Finished Goods Remained Un-Adjudicated.

Section 143(3)Section 92C

Date of Pronouncement 31.12.2025 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the final assessment order dated 30.01.2015 passed U/s 143(3) r.w.s.144C(1) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) in compliance to the direction given

Keyence India Private Limited, Chennai vs. Deputy Commissioner of Income Tax - Corporate Circle 4(1), Chennai

In the result, the appeal filed by the assessee stands dismissed as ‘withdrawn’

ITA 2017/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 Dec 2025AY 2020-21

Bench: Hon’Ble Shri George George K & Hon’Ble Shri Inturi Rama Raoassessment Years: 2020-21 M/S. Keyence India Private Limited, Deputy Commissioner Of Income 1St Floor, Unit C3 & C7, Tax, Skcl Triton Square, Corporate Circle-4(1), Thiru-Vi-Ka Industrial Estate, Guindy, Chennai. Chennai-600 032. [Pan: Aaeck4385P] Appellant) Respondent Assessee By : Mr.Rajesh, Advocate. Revenue By : Ms.R.Anitha, Addl.Cit Date Of Hearing : 19.12.2025 Date Of Pronouncement : 30.12.2025 O R D E R

For Appellant: Mr.Rajesh, AdvocateFor Respondent: Ms.R.Anitha, Addl.CIT
Section 143(3)

INTURI RAMA RAO, A.M : This appeal filed by the assessee – Keyence India Private Limited directed against the final assessment order of the Deputy Commissioner of Income Tax, Corporate Circle-4(1), Chennai dated 29.05.2024 for the assessment year 2020-21 passed u/s 143(3) r.w.s.144C(13) r.w.s. 144B

G S Strategic Investments Limited, Mumbai vs. ACIT International Tax Circle 2(3)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5644/MUM/2025[2023-24]Status: DisposedITAT Mumbai30 Dec 2025AY 2023-24

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 112Section 143(3)Section 144C(13)Section 74

Date of Pronouncement 30/12/2025 आदेश / O R D E R PER AMIT SHUKLA (J.M): This appeal by the assessee is directed against the final assessment order dated 14 July 2025 passed by the Assessing Officer under section 143(3) read with section 144C(13) of the Income ... necessary to point out that for the year under consideration, only the Applicant assessee has a right to appeal against the final assessment order framed by the AO after incorporating the directions of the DRP and the Department does not have any such right of appeal, apart from limited rights

Acronis Asia Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )Range-1(1)(1), Mumbai

In the result, the appeal filed by the assessee is

ITA 2035/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Dec 2025AY 2022-23
Section 10(50)Section 143(3)Section 144C(13)

18/11/2025 30/12/2025 आदेश / ORDER PER AMIT SHUKLA (J.M): This appeal has been preferred by the assessee, Acronis Asia Pte. Ltd., against the final assessment order dated 27 January 2025 passed by the Assessing Officer under section 143(3) read with section 144C(13) of the Income ... payment being Fees for Technical Services The amounts have, therefore, been rightly taxed as FTS. 12. Pursuant to the DRP's directions, the final assessment order was passed making the impugned addition. 13. Aggrieved by the said order, the assessee is now in appeal before this Tribunal. 14. Before adverting

Westcourt Hospitality Pvt Ltd, New Delhi vs. DCIT, Circle-25(1), Delhi

In the result appeal of the assessee is allowed

ITA 3351/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

received by him. As per the assessment order, SCN was issued on 15.01.2021 date of compliance was fixed for 21.01.2021. The final assessment order was passed on 09.02.2021. Furthermore, the evidence adduced only serve to aid the initial contention of the assessee regarding the source of funds. AO himself